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Compare cement environmental product declarations (EPDs) only after proving that they describe equivalent products delivering the same function. Then align the product category rules (PCRs) and versions, declared or functional units, life-cycle modules, system boundaries, scenarios, data quality, allocation rules, impact-assessment method, geography, and validity dates. A lower number is meaningful only after those checks; a shared label such as “cement EPD” or a common standards citation is not enough.
What an equal-basis comparison actually means
An EPD is a Type III environmental declaration prepared under rules that define what is measured and how it is modelled. Two declarations can therefore report different results for reasons unrelated to the cement itself. The products may serve different applications, use different units, cover different life-cycle stages, or apply different data and calculation rules.
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Construction-product comparison has to be made at the level where the products provide the same service. An AENOR cement declaration explains that products should have the same function and use the same declared or functional unit at building or works level. Read the comparison guidance in the CEM II/A-L Portland Monjos EPD before treating a numerical difference as a product difference.
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Start with cement type, strength class, intended applications, producer or site scope, and the technical performance required by the project. A general-purpose cement and a product intended for a different durability or strength requirement are not automatically interchangeable because both are sold as Portland cement. If one product requires a different mass, mix design, curing regime, or replacement rate to provide the required concrete performance, a tonne-to-tonne comparison does not describe equal service.
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Same comparison level
A declared unit is a reference quantity used for reporting. The American Cement Association gives one metric tonne as an appropriate example for cement-manufacturer reporting because cement is used in many applications; see its environmental-impact guidance. That is a product-level comparison. It is not automatically a comparison of the carbon or environmental performance of a completed building, where the amount and performance of cement needed to deliver the same concrete or structural function must also be considered.
Step 1: Identify the products and their intended use
Create a product record for each declaration before looking at impact results. Record:
- cement designation, composition and strength class;
- manufacturer, plant or plants covered, and whether the declaration is plant-specific, an average, or another group scope;
- markets and intended applications;
- technical standards, conformity information and performance data stated in the EPD;
- declared unit and any functional-unit definition; and
- the concrete, mortar or other application in which the cement will be used.
Sector-average and plant-specific declarations answer different questions. The Mineral Products Association UK publishes an Average CEM I Sector EPD; its average scope should not be interpreted as the footprint of one named plant. Conversely, a plant-specific EPD should not be presented as a sector average.
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If the declarations cover products with different performance or applications, either stop the comparison or explain the mismatch and use a functional calculation. A defensible calculation would determine the quantity of each cement needed to provide the same specified service, document the assumptions, and then compare the resulting environmental profile. Do not silently convert a mass result into a building-performance claim.
Step 2: Check the EPD programme, PCR and versions
Copy the declaration identity exactly. At minimum, record the programme operator, PCR title and version, standards cited, declaration number, publication or version date, and expiry or validity date.
| Item to record | Why it changes comparability | What to do |
|---|---|---|
| Programme operator | Programmes can set different verification, format and reporting rules. | Confirm both declarations belong to the same programme or that their rules are demonstrably aligned. |
| PCR title and version | PCRs define scope, modules, modelling and reporting requirements. | Match the exact title and revision; do not rely on a similar product name. |
| Standards and amendments | Different editions can change indicators, modules or calculation requirements. | Record every cited edition and amendment. |
| Declaration date and validity | Data, factors and programme rules can change over time. | Check that each EPD was valid on the date of comparison. |
For European cement declarations, EN 15804 is the core construction-product EPD standard and EN 16908 provides complementary cement and building-lime category rules. AENOR says its older GlobalEPD PCR 00 003 Cement was superseded by UNE-EN 16908:2019+A1:2022 on its cement-products panel page. Individual declarations must still be checked: the AENOR examples cite EN 16908:2017+A1:2022 together with EN 15804:2012+A2:2019 in the Portland Monjos EPD and the Mataporquera EPD. Do not assume that a citation to EN 16908 or EN 15804 means the same revision was used.
Confirm the validity window
Use the issue, version and expiry dates printed in each declaration. As a concrete example, the Mineral Products Association UK lists its UK Average CEM I EPD with a version date of 27 March 2024 and its UK Average Portland Cement EPD with a version date of 14 March 2024; both are shown as valid through 13 April 2027 on its EPD page. Those dates apply to those declarations only, not to every cement EPD. An expired declaration, or one issued under a superseded PCR, needs a current replacement or a documented programme-specific justification before use.
Step 3: Put results on the same declared or functional unit
Write the unit in full, including its mass basis, moisture convention where stated, and whether it represents a product mass or a service. The Polish Cement Association identifies 1 tonne as the product-mass reference unit for its CEM I–CEM V declarations on its EPD page. This illustrates a common reporting basis, but it does not make every tonne-based declaration functionally equivalent.
When conversion is legitimate
A unit conversion is defensible only when the underlying quantity and assumptions are known. Converting kilograms to tonnes is straightforward; converting a tonne of one cement into an equivalent amount of another product requires performance and formulation information. If the EPD does not state the data needed to establish equivalent service, report the declarations as different declared-unit results and do not rank them.
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Keep product and building claims separate
A result per tonne describes the reference cement amount. A project calculation must multiply that result by the amount of cement actually required and account for the concrete design, reinforcement, service life and other project conditions. The AENOR comparison principle is therefore important: equal comparison belongs at the building or works level when the question is which product provides the same construction function.
Step 4: Align life-cycle modules and system boundaries
First list the modules included in each EPD. Under EN 15804-style reporting, product-stage modules commonly include A1 raw-material supply, A2 transport and A3 manufacturing. Later construction, use, end-of-life and benefits-beyond-the-system-boundary modules may be included, excluded or marked as not evaluated.
One AENOR example includes A1, A2 and A3 while later stages are marked not evaluated. Its result is therefore a product-stage result, not a cradle-to-grave result. Compare it only with another declaration covering the same modules and boundary. The module status is shown in the Portland Monjos document.
| Boundary check | Question to answer |
|---|---|
| Raw materials and fuels | Are the same upstream inputs and extraction processes included? |
| Transport | Are inbound distances, modes, loads and destinations modelled on the same basis? |
| Manufacturing | Are kiln, grinding, electricity, fuels, process emissions and plant operations covered? |
| Construction, use and end of life | Are modules beyond A3 included in both declarations, or excluded from both? |
| Benefits or loads beyond the system boundary | Are credits calculated under the same rule and reported in the same module? |
Never label an A1–A3 comparison “full life cycle” unless both declarations actually include the later stages and the relevant scenarios.
Step 5: Reconcile modelling choices
After boundaries, inspect the assumptions that generate the inventory and impact results. Record differences instead of averaging them away.
Data sources and quality
Check whether each declaration uses primary plant data, sector averages, commercial databases or combinations of these; identify the reference years, geographic coverage, completeness and representativeness requirements. AENOR states that EPDs may not be comparable when the origin of the data differs, such as different databases. The same warning appears in its 2024 CEM II/A-L declaration.
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Allocation and co-products
Cement manufacture can involve shared processes, fuels, materials or outputs. Find the allocation hierarchy and rule used for electricity, alternative fuels, clinker, supplementary constituents, recovered materials and co-products. Two declarations can have identical boundaries but different allocations, making their results unsuitable for a simple ranking.
Cut-off rules
Read what is omitted under each declaration’s cut-off rule and whether the same threshold, treatment of recycled content and transport or infrastructure exclusions apply. A small-looking omission can matter when it is systematic or when comparing a product with a very different material composition.
Scenarios
Transport, construction, use and end-of-life modules depend on scenarios. Distance, mode, service life, replacement, demolition and waste-treatment assumptions must match the project or be equivalent between declarations. AENOR cautions that declarations may not be comparable when they are based on different scenarios, even within the same product category.
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Step 6: Match geography, indicators and characterization methods
Geography and regional modules
Electricity mixes, fuels, transport, raw-material supply and regulatory conditions vary by region. The American Cement Association explains that its GCCA environmental-product tool has a North American module following ISO 21930 and an International module following EN 15804. It reports some harmonization but keeps separate modules because differences remain; see Quantifying Environmental Impact. Do not mix a North American declaration with an International declaration merely because both report a tonne of cement. Use the framework applicable to the project and verify the rules in each EPD.
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Indicators and units
Choose the same indicator, unit and characterization method. Global warming potential (GWP) is commonly reviewed, but it is only one part of an environmental profile. Match the stated climate-change indicator and version of its characterization factors, then check acidification, eutrophication, resource use, water use and other reported indicators where the decision requires a broader assessment. A lower GWP value is not an overall environmental ranking when other indicators or assumptions differ.
A practical comparison worksheet
Use one row per declaration and complete every field before comparing numbers.
| Field | Declaration A | Declaration B |
|---|---|---|
| Product, cement type and strength class | Record exactly as stated | Record exactly as stated |
| Producer and site scope | Plant-specific, average or other scope | Plant-specific, average or other scope |
| Programme operator | Operator and programme | Operator and programme |
| PCR and version | Exact title and revision | Exact title and revision |
| Standards and amendments | All citations | All citations |
| Declared or functional unit | Unit and definition | Unit and definition |
| Modules and boundary | Included, excluded and not evaluated | Included, excluded and not evaluated |
| Geography and reference year | Country or region and data period | Country or region and data period |
| Data sources and quality | Primary, secondary and database details | Primary, secondary and database details |
| Allocation, cut-offs and scenarios | Rules and assumptions | Rules and assumptions |
| Indicator method | Indicator, unit and factors | Indicator, unit and factors |
| Issue, version and expiry | Dates and validity status | Dates and validity status |
Mark each row as aligned, different but adjustable, or not comparable. A numerical ranking is appropriate only when the material rows are aligned and any adjustments are transparent and reproducible.
How to interpret a numerical difference
- Confirm the comparison gate. Verify equivalent function, intended use, unit and technical performance.
- Confirm declaration status. Check PCR, programme, issue date and validity for both documents.
- Align the boundary. Remove or separately report modules that only one declaration includes.
- Align the model. Reconcile geography, data sources, allocation, cut-offs, scenarios and characterization factors.
- Compare the same indicator. Report the value with its unit, module scope and method version.
- Describe residual uncertainty. State which fields remain different and whether they could explain the observed gap.
If the declarations cannot be harmonized, the correct conclusion is not “Product A is better.” It is that the published EPD results are not directly comparable under the stated conditions. You may still use each EPD in a project life-cycle assessment, provided the practitioner documents the differences and models the products on a common project basis.
Common comparison mistakes and their fixes
- Ranking the smallest GWP number: compare the full relevant profile and confirm equal function first.
- Comparing different declared units: convert only with documented performance assumptions; otherwise do not rank.
- Treating A1–A3 as cradle to grave: label the result as product stage and match modules.
- Assuming one standard citation settles the issue: inspect PCR revision, programme rules, data, scenarios and geography.
- Mixing sector-average and plant-specific data: keep scopes separate and state what each declaration represents.
- Using an expired declaration: obtain a current version or document why the programme permits the older one.
- Combining regional frameworks casually: keep North American and International modules separate unless their rules and project context are demonstrably aligned.
How to present the result in a specification or report
State the comparison basis in the same paragraph as the result. Identify both products, their declared or functional unit, PCR and version, modules, geography, indicator and validity date. If the data are not fully aligned, show the unmatched fields in a table and describe the result as indicative rather than a product ranking.
A concise, defensible conclusion might read: “The two declarations use the same cement function, unit, PCR revision, A1–A3 boundary, regional framework and GWP method; the reported difference can therefore be interpreted within the remaining data-quality uncertainty.” If any of those conditions is not met, name the limitation instead of implying equal-basis evidence.
Bottom line
Equal-basis cement EPD comparison is a compatibility exercise before it is a mathematics exercise. Match function and performance, declaration identity, unit, boundary, modelling rules, geography, indicator method and validity. Only then should a lower reported impact influence a procurement, design or specification decision.
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