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BETTESWORTHConstruction
alternative cement

How to Check Whether Clinker-Free Cement Meets Project and Building-Code Requirements

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To determine whether clinker-free cement can be used on a project, start with the product’s exact composition and intended concrete application. Compare those details with the project specification, the locally adopted building and structural codes, and every referenced material standard. If the formulation falls outside a prescriptive specification, the project team must assemble application-specific performance evidence and obtain the approvals required by the jurisdiction before the material is specified or placed.

In practical terms, ask: “How do I check whether clinker-free cement meets my project’s specifications and building-code requirements?” The answer is a documented chain from formulation, to applicable standard, to test evidence, to written acceptance by the licensed design professional and building official.

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What “clinker-free” tells you—and what it does not

“Clinker-free” describes how a cementitious product is made, not a universal code category. Portland-cement clinker is the kiln-produced intermediate used in ordinary portland cement. A product marketed as clinker-free may instead rely on one or more supplementary cementitious materials, chemically activated industrial materials, calcined minerals, or another hydraulic or pozzolanic system. The label alone does not establish that the product is a cement recognized by the adopted code, that it conforms to an ASTM specification, or that it is suitable for a particular exposure or structural use.

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The controlling question is whether the complete formulation and its intended use fit a material specification referenced by the project’s adopted code and construction specification. A material can have a familiar ingredient and still fall outside the scope of the standard because the proportions, activation method, manufacturing process, or intended application differ.

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Classify the product before evaluating it. Ask the manufacturer to state, in writing, whether the product is:

  • a hydraulic cement sold for direct use in concrete;
  • a blended hydraulic cement that is intended to conform to a named ASTM specification;
  • an alternative supplementary cementitious material (ASCM) added to a conventional cement system; or
  • a proprietary binder that requires a manufacturer-supplied activator or a special mix design.

Those categories can trigger different provisions, test programs, submittal requirements, and approval routes. A product’s environmental claim or trade description cannot substitute for this classification.

Step 1: Identify the exact product and application

Do not begin with a generic search for “clinker-free cement approval.” Begin with a controlled product record. Request the current technical data and have the supplier identify the exact manufacturing source and formulation proposed for the project.

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Information to obtain from the supplier

  • Manufacturer’s legal name, product trade name, and product revision or date.
  • Complete formulation or material classification, including all principal constituents and any activator.
  • Whether the product is supplied as a cement, a blended cement, an ASCM, or a proprietary binder.
  • Manufacturing location, source materials, and controls used to keep composition consistent.
  • Intended concrete uses, including structural, nonstructural, precast, cast-in-place, pavement, shotcrete, or other applications.
  • Limits on cement replacement, water-to-binder ratio, admixtures, aggregate types, temperature, curing, and placement methods.
  • Storage, shelf-life, handling, batching, and quality-control requirements.
  • Current product data sheets, safety information, certificates of analysis, and available test reports.
  • Any evaluation report, listing, acceptance criterion, or prior jurisdictional approval, with its scope and conditions of use.

Require the supplier to identify what is actually being delivered. A test report for a laboratory formulation, a different production plant, or a different activation system is not automatically evidence for the proposed material.

Define the concrete use at the same time

Performance depends on the concrete, not only the powder. Record the specified strength and modulus, member type, reinforcement, placement method, curing regime, construction schedule, fire-resistance requirements, and exposure classes. Include freeze-thaw, deicing salts, sulfates, chlorides, carbonation, abrasion, elevated temperature, or chemical exposure where applicable. Note whether the concrete is in a critical structural member, a façade, a foundation, a slab, a pavement, or a nonstructural application. The evidence plan must match these conditions.

Step 2: Lock the governing project and jurisdiction documents

Model codes are not the same as law on a particular job. Confirm the documents in force where the work will occur and the editions named in the contract.

Project and code information to confirm

  • Project address and the building department or other authority having jurisdiction (AHJ).
  • Occupancy, construction type, risk category, and structural system.
  • Locally adopted building-code edition and amendments.
  • Locally adopted structural-concrete code edition and referenced standards.
  • Referenced ASTM editions in the project specification, including any owner or agency amendments.
  • Exposure classes, durability provisions, fire-resistance and testing requirements.
  • Specified cement types, supplementary cementitious materials, minimum binder content, strength at stated ages, and curing requirements.
  • Owner standards, insurer requirements, transportation-agency provisions, or other contract conditions.
  • Required submittal, special-inspection, testing-agency, and record-keeping procedures.

Record the edition and adoption date for every document. An older code summary may explain the approval concept but cannot prove that the same language is currently adopted. The International Code Council’s overview of alternative cement use under ACI 318-19 is useful background, but the project team must verify the current local code and its amendments before relying on it.

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Step 3: Check prescriptive scope before seeking an alternative-material approval

Compare the supplier’s complete formulation and intended use line by line with each applicable specification. Check definitions, constituent limits, physical and chemical requirements, test methods, labeling, and permitted uses. Do not treat a similar ingredient, a “green cement” description, or a passing strength result as proof of conformity.

How the principal ASTM pathways differ

Reference What it addresses What it does not establish Action for the project team
ASTM C595/C595M Certain blended hydraulic cements using slag, pozzolan, limestone, or combinations with portland cement or clinker. It does not automatically cover every clinker-free formulation, activation chemistry, or proprietary binder. Check the edition adopted by the project and verify that the exact composition and intended use fit its scope and requirements.
ASTM C1709-22 A guide for evaluating alternative supplementary cementitious materials outside specified ASTM material standards. It is guidance, not a code approval, and its tests do not establish conformance to a named specification or evaluate every possible performance criterion for every mix. Use it to organize a comprehensive, use-specific evaluation with the design professional and testing team.
ICC-ES AC529 An evaluation criterion announced for low-carbon alternative cements used in concrete, including products activated by water or a proprietary manufacturer-supplied activator. The criterion or an announcement does not prove that a particular product has an evaluation report or that every jurisdiction accepts it. Review the current criterion and the actual evaluation report, including formulation, applications, code editions, limitations, and conditions of use.

The ASTM C595/C595M page often consulted by specifiers is for the 2016 edition and lists newer editions, including C595/C595M-26. Use the edition actually adopted for the project rather than assuming that a web page’s historical edition governs. If the product does not fit the adopted specification’s scope, document that conclusion and move to an alternative-material pathway instead of calling it compliant.

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Step 4: Build a performance-evidence plan for an out-of-scope product

When a clinker-free formulation is outside a prescriptive specification, the design professional and AHJ should define the evidence needed for the actual project. ASTM C1709-22 is a useful framework for evaluating alternative supplementary cementitious materials, but it is not a universal test checklist. It emphasizes that the material’s source and intended use must be evaluated and that missing long-term durability or acceptable field performance requires risk management and engineering judgment.

ASTM C1709-22 states: “In the absence of long-term durability or acceptable field performance, prospective users are advised to apply appropriate risk management and engineering practice in the use of an ASCM.” Attribute that sentence to ASTM C1709-22, Section 4.3, when quoting it in a project record.

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Fresh-concrete behavior

Evaluate the properties that control batching and placement, such as water demand, slump or flow retention, setting time, temperature rise, air entrainment, bleeding, segregation, pumpability, finishability, and compatibility with chemical admixtures. Test the proposed mix proportions, not only a neat binder paste. Establish how changes in aggregate moisture, batch temperature, mixing energy, and delivery time affect the result.

Strength and hardened properties

Define the required ages and acceptance criteria for compressive strength and, where relevant, splitting tensile strength, flexural strength, modulus of elasticity, shrinkage, creep, permeability, and bond-related behavior. If the structure relies on early stripping, post-tensioning, traffic opening, or a rapid construction sequence, test the age that controls that operation rather than relying solely on 28-day results.

Durability for the specified exposures

Match testing to the exposure classes and service life expected for the project. Depending on the design, the program may need resistance to freeze-thaw cycling, deicing chemicals, chloride ingress, sulfate exposure, carbonation, alkali-silica reaction, abrasion, wet-dry cycling, or other mechanisms. A test that is irrelevant to the project does not compensate for an untested critical exposure. Long-term data may be limited for a new formulation; identify that limitation, set conservative conditions, and obtain the engineer’s documented risk decision.

Structural and fire performance

Confirm that the design assumptions for the concrete remain valid. The engineer may need evidence for cracking, deflection, anchorage, bond, member strength, and prestressed or reinforced-concrete behavior. Where a fire-resistance rating is required, address the applicable fire tests, temperature effects, spalling risk, and code calculation method. Do not infer fire compliance from ordinary compressive-strength data.

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Production consistency and quality control

Require evidence that the material tested is representative of what will be delivered. Review constituent acceptance, batch records, sampling frequency, calibration, traceability, nonconformance procedures, and statistical control. Establish what happens when a shipment falls outside the approved range and who has authority to stop production or placement.

Construction procedures and curing

Write the approved mixing sequence, dosage, activator handling, delivery limits, placement temperature, finishing window, curing method, curing duration, protection from drying or freezing, and testing frequency into the submittal. A formulation that performs in a controlled laboratory cure may require different field protection. Include mock-ups or trial placements when the finish, pumping, mass-concrete temperature, or schedule creates additional risk.

Step 5: Check evaluation reports and current criteria carefully

An evaluation report can consolidate evidence, but its scope controls. Obtain the complete report, not just a product summary, and verify:

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  • the exact product name, formulation, manufacturing facility, and activator;
  • the concrete applications and exposure limits covered;
  • the code editions and standards used for the evaluation;
  • required mix proportions, strength levels, curing, and inspection;
  • limitations, expiration or renewal status, and conditions of use;
  • who is responsible for quality control and field verification.

ICC-ES announced AC529 on February 16, 2022 as an evaluation criterion for low-carbon alternative cements used in concrete, including water-activated products and systems using a manufacturer-supplied proprietary activator. The announcement created a way to evaluate products; it did not grant blanket approval to every clinker-free cement. Confirm that the current criterion and the actual report cover the proposed formulation and project.

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Do not rely on ICC 1155 as an active approval route

The International Code Council reported on May 13, 2026 that its Board had resolved on April 18, 2026 to sunset ICC 1155, the Standard for Low-Carbon Alternative Cements Used in Concrete (IS-LCCC), and its committee. Do not present ICC 1155 as an active, generally available path without checking for a later replacement or update. A project team should ask the AHJ and evaluation body which current criterion, standard, or report they will recognize.

Step 6: Obtain the approvals required by the project and AHJ

Alternative-material acceptance is a decision by the parties empowered under the adopted code and project contract. The supplier and concrete producer provide data; they do not unilaterally approve the material for a building.

Licensed design professional

The engineer or architect responsible for the design must determine whether the evidence supports the intended use, revise calculations or specifications where necessary, and issue a written acceptance or design directive. The professional should identify conditions such as minimum strength, exposure restrictions, curing, testing, inspection, and permitted substitutions.

Building official or other authority having jurisdiction

The building official decides whether the submittal satisfies the jurisdiction’s alternative-material provisions. Requirements may include an evaluation report, testing by a qualified laboratory, special inspection, site-specific conditions, or a formal application. Approval in one city or state does not automatically transfer to another.

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Concrete producer and testing agency

The producer must demonstrate that the approved mix can be batched and controlled consistently. The testing agency performs the specified sampling and tests under the required qualifications and standards. Coordinate responsibilities before the first pour so that failed tests, material substitutions, and batch traceability have a defined response.

New York City example—not a national rule

New York City’s Department of Buildings illustrates how specific a local process can be. Its alternative-to-code material process calls for relevant acceptance criteria or a standard, an OTCR1 application, and testing or listing under approved criteria. The department also describes a site-specific route for certain materials and one-time project use. This is a local example only; another jurisdiction may use different forms, offices, criteria, or review steps.

Step 7: Assemble a complete submittal before specifying or placing

Submit one coherent package rather than disconnected laboratory reports. A practical package should contain:

  1. Product identity, formulation, source, safety information, and manufacturer’s installation instructions.
  2. Project description, structural role, exposure conditions, fire requirements, and proposed concrete applications.
  3. Applicable code, specification, and ASTM editions, with a scope comparison showing which requirements are prescriptive and which require alternative approval.
  4. Mix designs, trial-batch results, production controls, curing procedures, and proposed field-testing frequencies.
  5. Fresh, strength, durability, structural, and fire evidence selected for the project’s risks.
  6. Evaluation criteria or reports, with all limitations and conditions of use highlighted.
  7. Quality-control plan for constituent acceptance, batch traceability, nonconformance, and change control.
  8. Written design-professional rationale, calculations or revised details, and conditions of acceptance.
  9. AHJ forms, testing-agency qualifications, special-inspection plan, and written building-department decision.
  10. Approved mix design and a record of every revision, shipment, test result, inspection, and acceptance condition.

Do not place the material while an approval is merely anticipated. If the product, plant, activator, dosage, or exposure changes, treat the change as a new technical review unless the approval expressly permits it.

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How to compare two clinker-free products or approval pathways

Use identical decision criteria for every candidate. A lower embodied-carbon claim is relevant only after technical suitability and code acceptance are established.

Comparison axis Questions to answer
Code and specification scope Which adopted code provisions and material standards apply? Does the exact formulation fit, or is an alternative approval required?
Evaluation coverage Is there a current evaluation report or criterion? Does it cover the product, plant, activator, applications, code editions, and exposures proposed?
Performance evidence Are fresh, strength, durability, structural, and fire requirements addressed for this project rather than for a generic laboratory mix?
Source and batch control How are constituents controlled, lots traced, and formulation changes managed?
Construction implications What changes are required for mixing, pumping, finishing, curing, testing, cold weather, hot weather, or the construction schedule?
Approval route Which professional must accept the material, which AHJ reviews it, what forms and inspections are required, and how long can review take?
Environmental documentation What verified environmental information is available after the material has met technical and code requirements?

Common failure modes and how to correct them

Failure: treating the marketing label as a standard

Symptom: The submittal says “clinker-free” but names no material classification or applicable specification.

Correction: Obtain the complete formulation and classify the product as cement, blended hydraulic cement, ASCM, or proprietary binder before reviewing compliance.

Failure: citing the wrong ASTM edition

Symptom: A submittal relies on an older web page or a standard edition that the contract did not adopt.

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Correction: Confirm the project’s adopted edition and amendments, then compare the product with that edition’s scope and requirements. The C595/C595M page for the 2016 edition lists newer editions, including C595/C595M-26; the applicable edition is the one governing the project.

Failure: using a laboratory result as universal proof

Symptom: One compressive-strength series is offered for a project with demanding durability, fire, or schedule requirements.

Correction: Build a use-specific evidence plan with the design professional, including the exposures and construction conditions that control risk.

Failure: assuming an evaluation criterion equals an evaluation report

Symptom: AC529 is cited without a report identifying the exact product and conditions.

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Correction: Obtain the current report and verify formulation, facility, uses, limitations, code editions, and inspection requirements.

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Failure: relying on an obsolete approval path

Symptom: The package presents ICC 1155 as an active standard after its sunset decision.

Correction: Confirm the current replacement, criterion, or AHJ process before preparing the submittal.

Failure: assuming another jurisdiction’s approval transfers

Symptom: A product approved for one city is specified without contacting the local building department.

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Correction: Ask the actual AHJ for its current alternative-material process, required forms, testing, listings, and inspections. The New York City OTCR1 route is not a national template.

Failure: changing the material after approval

Symptom: The producer changes source, activator, dosage, or plant to solve availability or batching problems.

Correction: Stop and obtain written confirmation that the change remains within the approval; otherwise repeat the affected evaluation and acceptance steps.

Maintain the decision record through construction

Keep the approved code and specification editions, product submittal, formulation declaration, test reports, evaluation report, mix design, design-professional decision, AHJ approval, inspection plan, batch records, and field-test results together. Record the conditions under which the material was accepted, including curing, exposure limits, strength milestones, and required inspections.

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At closeout, retain evidence that the material actually placed matches the approved product and source. Include nonconformance reports, corrective actions, rejected loads, approved substitutions, and final test results. This record protects the owner and design team if a question arises years after placement and makes future projects easier to evaluate without treating the earlier approval as automatic permission for a different formulation or jurisdiction.

Decision checklist

  • Exact product, formulation, source, and intended use are identified.
  • Project location, occupancy, construction type, exposures, fire needs, and structural role are documented.
  • Locally adopted code, concrete-code, ASTM, and specification editions are confirmed.
  • Prescriptive scope has been checked before an alternative route is selected.
  • Out-of-scope performance evidence is tailored to the proposed concrete and exposures.
  • Any AC529 report or other criterion is current and covers the exact product and conditions.
  • ICC 1155 is not being treated as an active approval path without current confirmation.
  • Licensed design-professional acceptance is documented.
  • Building-official or AHJ acceptance is obtained through the local process.
  • Producer quality control, testing, inspection, curing, and change-control requirements are written and funded.
  • No material is specified or placed until all required conditions are satisfied.

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