Citation: Michalak, J. Sustainability
Assessment of Cementitious Ceramic
Tile Adhesives. Buildings 2023,13,
Academic Editors: Paulo Santos and
Received: 4 April 2023
Revised: 11 May 2023
Accepted: 14 May 2023
Published: 19 May 2023
Copyright: © 2023 by the author.
Licensee MDPI, Basel, Switzerland.
This article is an open access article
distributed under the terms and
conditions of the Creative Commons
Attribution (CC BY) license (https://
Sustainability Assessment of Cementitious Ceramic
Research and Development Center, Atlas sp. z o.o., 2 Kili ´nskiego St., 91-421 Lodz, Poland; email@example.com
This article presents the results of analyzing environmental impact indicators of thirteen
ceramic tile adhesives (CTAs). The analyzed data came from ten third-party-veriﬁed Environmental
Product Declarations (EPDs) created in 2016–2022. The paper examines seven environmental impact
indicators for modules A1–A3 (cradle-to-gate). Signiﬁcant differences were observed between the
values of environmental indicators, which, in the case of Global Warming Potential (GWP), differed
by almost 270% in the most extreme case. For the depletion of abiotic resources (elements) (ADP
the values of products differed by nearly fourteen thousand times. Results are discussed from the
perspective of the CTAs’ manufacturer assessing the product. The analysis focused on issues such as
the historical dimension of data, which is the basis for Life Cycle Assessment (LCA), the need for
their constant updating, and the subject of uncertainty—usually wholly omitted in the considerations
on the environmental impact of construction products. The results of the analysis were also evaluated
in terms of the planned introduction of the new 3+ assessment system in connection with the future
amendment of the Construction Products Regulation (CPR). The results of the CTAs’ analysis of
environmental indicators showed that, despite the EPDs functioning for a decade, the obligatory
assessment of construction products in terms of sustainability using the 3+ system did not create the
conditions for its proper occurrence. This analysis showed that, without obtaining reliable data on
the environmental impact of CTAs, correct AVCP is not possible, and the consumer is not able to
make proper choices.
sustainability; construction products; ceramic tile adhesive (CTA); assessment and
verification of constancy of performance (AVCP); Environmental Product Declaration (EPD)
The construction sector, which consumes vast amounts of raw materials, produces
large quantities of waste, and emits signiﬁcant amounts of greenhouse gases, is one of the
branches of the economy with a fundamental impact on the natural environment. Ofﬁcial
statistics say that construction consumes the most considerable quantity of raw materials,
emits the most greenhouse gases, and produces the most waste among all branches of the
]. In 2020, buildings and all related operations in the 27 European Union
(EU) countries were responsible for 511 Mt CO
eq., which accounted for 15% of global
emissions. EU 2020 emissions were 24% lower than in 2005, but by 2030 they must decrease
by 20% to meet the targets set by the European Commission (EC) [
]. Achieving the goals
set by the EC is possible through further reduction in energy consumption of buildings,
decarbonization of energy sources, optimization of the use of renewable energy sources,
reduction in emissions resulting from the operation of buildings and facilities, and reduction
in the negative environmental impact of construction products and construction works
at the erection, renovation, and disassembly stages. In 2017, building materials were
responsible for 11% of global CO2emissions .
Buildings 2023,13, 1326. https://doi.org/10.3390/buildings13051326 https://www.mdpi.com/journal/buildings
Buildings 2023,13, 1326 2 of 17
1.1. Construction Products in the European Union
In EU countries, the principles of construction product assessment and veriﬁcation
of constancy of performance (AVCP) inform the Construction Products Regulation (CPR).
According to the CPR, construction works must be designed, constructed, and dismantled
in such a way that the use of natural resources is sustainable and ensures their re-use or
recycling, the construction works are durable, and environmentally friendly raw materials
and recycled materials are used in their construction [
]. Despite the importance of envi-
ronmental assessment of construction products [
], positive political trends [
], and the
need to protect the environment, environmental impact assessment is still not mandatory
in the AVCP process [
]. It is common to expect that environmental assessment should be
required, and such expectations are powerfully articulated by the scientiﬁc community [
The European Commission, taking into account scientists’ and ecologists’ expectations,
and in line with its environmental policy, published a proposal on 29 March 2022 for a
regulation laying down harmonized conditions for the marketing of construction products,
amending Regulation (EU) 2019/1020 on market surveillance and compliance of products,
and repealing CPR [
]. The CPR, and, thus, its novelization, is of fundamental importance
for the construction products market in the EU. It assumes a signiﬁcant change involving
introducing a new assessment system to the AVCP—the 3+ system. In this system, the
manufacturer shall assess construction product performance concerning essential character-
istics or product requirements related to environmental sustainability and keep it updated.
The notiﬁed body controls environmental sustainability assessment, namely, it givesn input
values, assumptions, and compliance with applicable generic or product category-speciﬁc
rules. The notiﬁed body also veriﬁes the manufacturer’s initial and updated assessment
and validates the process to generate that assessment. On the one hand, changes are needed
and expected, but revolutionary changes also raise questions: are they feasible for the
manufacturer, and possible for notiﬁed bodies?
1.2. Sustainability and Construction Products
One needs to consider the environmental impact issue in the broader aspect of develop-
ing contemporary strategies that directly link core businesses and sustainability issues and
clearly articulate their limitations [
]. Years of industry experience with certiﬁed manage-
ment systems are primarily associated with bureaucracy, and often with the abandonment
of innovative thinking [
]. All of the construction sector’s partner actors and governments
must understand and participate in the new sustainable business development [
need to change the attitudes of scientists has also been postulated [
], especially when
considering the scenarios in which economic growth is a lower priority than sustainability.
This, and even more critical ideas, are currently far from being understood [
pathways for sustainability transformation are found in macro-level discussions on pol-
icy, science, and business [
]. One important issue is the mutual relationship between
a circular versus a linear building element [
]. The European Commission, recognizing
the issue’s importance, already in 2004 gave CEN a mandate to develop standards for
integrated environmental building performance [
]. One of the results of the work of CEN
experts is the possibility of using Life Cycle Assessment (LCA) to assess the impact of a
construction product on the environment using type III Environmental Product Declaration
]. In 2006, the ISO organization deﬁned the procedures and requirements for
preparing EPDs for all product types .
In 2011, the EU initiated work under the Single Market for Green Products Initiative,
aimed, among other things, at using known methods for measuring and informing about
environmental performance in the life cycle of products—Product Environmental Footprint
(PEF) [22,23]. Both approaches (EPD and PEF) have since been amended [24–27].
EPDs should provide quantiﬁable, reliable, coherent, and comparable environmental
information on construction products on a scientiﬁc basis. Ten years after the publication of
EN 15804, which deﬁned the guidelines for developing EPDs for construction products, in
January 2023, over sixteen thousand veriﬁed EPDs for construction products were registered
Buildings 2023,13, 1326 3 of 17
]. From this number, the most signiﬁcant number of EPDs for construction
products was issued by the French FDES—4585—followed by International EPD—2945—
Norwegian EPD Norge—1977—and IBU (Germany)—1302. The Polish Research Building
Institute (ITB) took thirteenth place in this ranking, with 263 issued EPDs [
the distribution of EPDs is not homogeneous across EU countries and European regions,
remaining limited in terms of the type of construction products [
]. Three Nordic countries,
i.e., Denmark, Finland, and Sweden, are leaders in implementing environmental policies
and regulations [
]. The analysis of construction product EPDs in Spain showed that
20% of construction products used in buildings could use data from EPDs to conduct a
building LCA [
]. Additionally, the view, supported by the results of the analyses, that
environmental data are considered valid only for comparative purposes since they differ
from one region/country to another, is critical [
]. For this reason, the institutional role
of industry associations is essential, which can partially explain cross-national or cross-
regional variations [
]. It is also important that small and medium-sized enterprises
may not meet the requirements for the environmental assessment of their products due to
insufﬁcient ﬁnancial, technical, and human resources .
Even when operators of EPD programs work according to the same guidelines based
on identical Product Category Rules (PCR), the published EPDs differ. Often these differ-
ences are so signiﬁcant that they prevent proper product assessment and confuse users [
This is the case even though PCR determines the LCA calculation rules (allocation, col-
lection, system boundaries, environmental indicators, EPD format). Europe is a leading
continent in the ﬁeld of knowledge on the environmental impact of construction products
because of the activities of the ECO Platform EPD, thanks to which a greater consensus on
communicating environment information has been developed than on other continents [
However, global scale harmonization is still the primary challenge faced by all who want
to increase the signiﬁcance and comparability of EPDs [
]. The ﬁrst information on dif-
ferences in the quality of LCA studies appeared shortly after the publication of the ﬁrst
]. Differences between EPDs for different groups of products are the subject of
research by many researchers [
]. The defective part of the current EPD scheme is the
interpretation of the results [
]. It is also worth mentioning that the multitude of EPDs
impact categories and the units in which individual environmental indicators are expressed
are challenging to communicate and, thus, difﬁcult to understand, creating a complex
decision-making process [
]. Comparison of data contained in EPDs is often tricky be-
cause environmental impact values are calculated for different functional units [
current state of the comparability of data contained in the EPD is illustrated by the analysis
of 436 EPDs veriﬁed by two renowned operators (International EPD System, Insitute Bauen
und Umwelt e.v.) for the categories boards, thermal insulation, and ﬂoor covering. Of the
analyzed EPDs, only 0.04% of documents were fully comparable, 2.75% could be compared
with caution, as much as 89.15% should be treated as incomparable, and 8.06% EPDs could
not be compared in any aspect [
]. It should also be remembered that the LCA analysis of
construction products ignores the share of components whose content is below 0.5%, some
impacts are avoided, and different inclusions of recycled materials are applied .
It is also worth noting that environmental indicator analysis primarily concerns the
Global Warming Potential (GWP) indicator [
]. Importantly, EPDs often did not cover
the mandatory scope of the scheme [
]. Other studies have indicated that as long as
the databases are representative of the context, methodological choices may be a minor
]. In connection with the problems described above, attempts have been made
to develop a new environmental scoring methodology for construction products based on
]. Benchmarking methods are also used regarding their applicability to the EPD’s
PEF—the second approach to the environmental assessment of products—is less
popular and, like EPDs, is not free from imperfections [
]. As if that were not enough,
comparing the results obtained with the EPD and PEF methods is complex and sometimes
Buildings 2023,13, 1326 4 of 17
even impossible due to the different system boundaries and source data used. Thus, the idea
of alternative use of the two mentioned methods cannot be implemented in practice .
Summing up the decade of functioning type III EPDs, one can say that the use of these
documents is still limited and is primarily used for B2B communication, and preparation
of offers for tenders and voluntary building certiﬁcation systems, such as BAMB, BREEAM,
CASBEE, DGNB, Green Globes, HQE, LEED, ÖGNI, SBTool, and TQB [
product weights in the previously mentioned certiﬁcation systems are between 12.5% and
]. It is also important to note the importance of assessing the environmental
impact using the certiﬁcation systems mentioned above for buildings under renovation,
and not only the construction of new ones [
]. EPDs should also be implemented in
building information modeling (BIM), which is the foundation of digital transformation
in the architectural, engineering, and construction industries, including identifying the
main interaction problems between BIM and the LCA [
]. In this aspect, it is crucial to
integrate databases with BIM to extract quantities and calculate the construction products’
environmental impact at the design stage [
]. Published in 2022, ISO 22057 provides
the principles and requirements to enable environmental data in EPDs for construction
products to be used in BIM [
]. Additionally, ISO 22057 describes the weaknesses of
existing digitized EPD approaches .
Most EU countries do not have central LCA repositories. This lack creates barriers to
developing benchmarks .
Despite the shortcomings mentioned above in the environmental assessment of prod-
ucts using EPDs, it is clear that it is necessary to develop this path—more EPDs must be
]. The analysis of data contained in EPDs over the years allows the identifying
of current trends or relationships between various environmental indicators [
more EPDs become available, the more accurate the results will be and, thus, the easier it
will be to implement artiﬁcial intelligence techniques to predict environmental impacts,
including construction products [
]. Another view, presented by Wittmayer and Schäpke,
is that it is necessary to move to more process-oriented approaches [
]. Without proper,
i.e., high-quality, EPDs, it will not be possible to signiﬁcantly improve the environmental
performance of construction projects .
1.3. Sustainability of Construction Products by Manufacturers
Most studies on EPD, LCA, and the circular economy do not consider the industry, or
do so only to a small extent. However, symbiosis in the industrial dimension is necessary
between feedstock, technology, products, side streams, downstream valorization, and
long-term circularity [
]. An analysis of literature on the subject clearly shows that the
discussion on making EPDs more coherent and comparable does not involve industry, but
]. Additionally, other earlier studies prove that construction sector practices
are often removed from academic research [
]. In addition, when considering the percep-
tion of the industry in terms of broadly understood environmental protection by various
stakeholders, including science, it is worth mentioning “greenwashing”, i.e., a situation in
which, taking into account the current trends in terms of being sustainable, the companies
themselves, when reporting data, present them not necessarily as they are, and more as
commonly expected [
]. EPDs as a communication tool are believed to give companies a
competitive advantage .
A completely different issue than the issues raised above is environmental impact
assessment as a part of the manufacturer’s AVCP of construction products. It is an en-
tirely different issue from the challenges faced by building LCA practitioners for whom
recommendations can be found in the literature [
]. It is essential to add that, in the
wealthy scientiﬁc literature on the environmental assessment of construction products,
there is practically no work on this issue from the perspective of the manufacturer of the
Buildings 2023,13, 1326 5 of 17
1.4. Research Hypothesis
This article analyzes third-party-veriﬁed EPDs for thirteen cementitious ceramic tile
adhesives (CTAs). CTAs are essential construction products, and the reason for selecting
them for the research presented in this article is, above all, the fact that they contain
relatively few ingredients in their composition, and their performance properties are clearly
deﬁned in EN 12004:A1:2012 [
]. The primary ingredient is Portland cement, for which
the environmental impact is the subject of intensive research by many centers and is well
]. Of course, there are differences in the environmental impact ratings of
Portland types of cement depending on who conducted the analysis. Still, there is general
agreement that the reasons for the differences are known [
]. Given the above, CTAs of
different origins can be deﬁned as comparable products.
The study results were analyzed from the perspective of the manufacturer performing
AVCP of CTAs, with particular emphasis on the conditions that will arise in the event of
introducing a new assessment system, i.e., the 3+ system.
The research hypothesis is that the model for assessing the environmental impact of
construction products using EPDs does not provide consistent and comparable data that
all participants in the construction market can use.
2. Materials and Methods
CTAs are commonly used to install ceramic tiles on walls and floors, indoors and
]. Global production of CTAs in 2020 was approximately 65 million tons [
basis of the AVCP of CTAs in the EU area is the requirements contained in EN 12004:2007 +
]. Similar provisions have been adopted by the ISO organization [
]. Thus, these
exact requirements apply to CTAs around the world. It is also worth mentioning that the
requirements underlying the AVCP of the CTA process have been practically unchanged in
the EU since 2001 .
The subject of the analysis presented in this article was data for CTAs coming only
from third-party-veriﬁed EPDs. The following extracting criteria were taken into ac-
count when collecting data: EPD owner—company/association, EPD program, product
identiﬁcation—type according to EN 12004/ISO 13007-1, validation from/to date, geo-
graphical representativeness, including the origin of the data used, temporal coverage,
compliance with EN 15804 and ISO 14025, PCR, declared functional unit, LCA database,
LCA software, system boundaries, end of life scenarios, and environmental impacts.
In addition to the EPD databases search and literature research, this study was con-
ducted based on the author’s almost thirty years of professional experience with the
assessment and veriﬁcation of constancy of performance of construction products.
The systematic search of the EPD programs resulted in 10 EPDs. In this article, data on
thirteen CTAs were analyzed—in the case of one EPD, data for three CTAs were selected
for analysis, and in the case of another EPD, data for two CTAs. From the remaining eight
EPDs, data for one CTA from each declaration were used for analysis. All 13 analyzed
CTAs contained gray Portland cement as a mineral binder, and CTAs containing white
cement were not analyzed.
Table 1summarizes the primary data characterizing the EPDs of the thirteen analyzed
CTAs, which for this study have been marked with letters of the alphabet from A to M.
Buildings 2023,13, 1326 6 of 17
Primary data on EPDs, of which data on 13 CTAs are the subject of the analysis presented in
CTA Valid (from–to) Dataset Geographical
A 05.2016–05.2021 2011–2015 generic and manufacturer data
+ literary research EU IBU assoc. 
B 09.2016–10.2023 * 2004–2018 generic data
+ 2017–2018 data from 2 locations in Italy Int. EPD Int. AB mfr. 
C 08.2017–06.2022 2016 data from 2 locations in Italy
+ generic data Global EPD Int. AB mfr. 
D 09.2016–06.2024 * 2005–2017 generic data
+ 2015–2017 data from 2 locations in Italy Int. EPD Int. AB mfr. 
E 12.2019–12.2024 2013–2018 generic data
+ 2018 data from 6 locations in Turkey TR EPD Int. AB mfr. 
F, G, H 01.2017–01.2022 2015 data from 4 locations in Turkey
+ generic data WW EPD TR mfr. 
I 11.2020–11.2025 2019 data from 5 location in Poland
+ 2017 generic data PL ITB mfr. 
J 11.2020–11.2025 2019 data from 5 location in Poland
+ 2017 generic data PL ITB mfr. 
K 09.2016–12.2022 2014–2015 data from ten producers,
except cement—2004 data + generic data CA, MX, US UL Env. assoc. 
L, M 03.2022–no date 2021 data from one location in Israel
+ 2011–2018 generic data IL IIS mfr. 
Abbreviations: EU (European), Int. (International), TR (Turkey), WW (Worldwide), PL (Poland), CA (Canada),
MX (Mexico), US (United States), IL (Israel), IIS (The Israeli Institute of Standards), assoc. (association), mfr.
(manufacturer), * EPDs revised in 2019.
Of the ten analyzed EPDs, only one followed ISO 14025, and the remaining nine were
under ISO 14025 and EN 15804. Among the analyzed CTAs, in the case of the product
marked as F, no classiﬁcation was given following EN 12004/ISO 13007-1, but from other
entries in the EPD it can be concluded that it is a class C1 CTA. In the case of the product
marked as K, the CTA marking per ISO 13007-1 was not provided, although the EPD
contains a record that the product complies with this standard’s requirements, but without
specifying which ones. For the CTAs marked A, B, D, E, F, G, H, I, J, and K, 1 kg is given
as the functional unit. In the case of CTAs marked as C, L, and M, 1 m
was indicated as
the functional unit while stating in the EPD that in the case of product C, it corresponds to
3.13 kg of dry product, which is equivalent to 2.5 mm thickness, and for the CTA marked
as K equals 4.2 kg of dry product and 3 mm thickness. For the CTA marked M, 3.9 kg of
dry product is required to cover 1 m
of the surface with a 3 mm layer. The information
provided allows for the calculation of the environmental impact for a functional unit
deﬁned as 1 kg of CTAs.
Table 2summarizes the environmental impact indicators—six mandatory categories
that shall be included in an EPD according to clauses 6.5 and 18.104.22.168—Table 3 of EN
15804:2012+A2:2019, i.e., Global Warming Potential (GWP), Ozone Depletion Potential
(ODP), Acidiﬁcation Potential (AP), Eutrophication Potential (EP), Photochemical Ozone
Creation Potential (POCP), depletion of abiotic resources (elements) (ADP
), and depletion
of abiotic resources (fossil) (ADP
). In the analysis presented in this article, only the produc-
tion stage, covering cradle-to-gate—A1–A3 modules, i.e., A1—extraction, and processing
of raw materials and the processing of secondary materials, A2—transport of the materials
to the manufacturer, and A3—production processes, was analyzed.
Buildings 2023,13, 1326 7 of 17
Table 2. Summary of environmental indicators of thirteen analyzed CTAs.
CTA GWP ODP AP EP POCP ADPeADPff
[kg CO2eq.] [kg CFC11 eq.] [kg SO2eq.] [kg (PO4)3−eq.] [kg ethene eq.] [kg Sb eq.] [MJ]
A6.38 ×10−15.14 ×10−92.03 ×10−31.82 ×10−41.92 ×10−41.06 ×10−67.09
B4.75 ×10−11.76 ×10−84.25 ×10−41.58 ×10−43.13 ×10−41.46 ×10−75.60
C5.69 ×10−13.45 ×10−81.77 ×10−34.09 ×10−41.16 ×10−46.74 ×10−76.93
D3.35 ×10−11.50 ×10−82.42 ×10−41.24 ×10−41.50 ×10−48.88 ×10−82.72
E2.98 ×10−11.58 ×10−88.21 ×10−43.36 ×10−49.06 ×10−71.15 ×10−71.79
F3.06 ×10−11.47 ×10−83.01 ×10−57.00 ×10−41.94 ×10−42.18 ×10−71.67
G4.71 ×10−12.87 ×10−89.41 ×10−51.28 ×10−33.54 ×10−49.68 ×10−73.86
H3.55 ×10−11.93 ×10−85.59 ×10−58.85 ×10−42.49 ×10−46.28 ×10−72.49
I4.35 ×10−11.90 ×10−84.75 ×10−43.64 ×10−47.73 ×10−51.23 ×10−32.47
J4.31 ×10−12.00 ×10−85.31 ×10−42.92 ×10−49.71 ×10−57.30 ×10−42.62
K5.19 ×10−11.08 ×10−92.33 ×10−31.87 ×10−41.68 ×10−47.11 ×10−74.25
L2.37 ×10−11.72 ×10−89.38 ×10−41.06 ×10−47.86 ×10−42.19 ×10−64.26
M5.77 ×10−13.28 ×10−81.85 ×10−33.43 ×10−41.59 ×10−33.05 ×10−66.49
Abbreviations: CTA (Ceramic Tile Adhesive), GWP (Global Warming Potential), ODP (Ozone Depletion Potential),
AP (Acidiﬁcation Potential), EP (Eutrophication Potential), POCP (Photochemical Ozone Creation Potential),
ADPe(Abiotic Depletion Potential (elements)), ADPff (Abiotic Depletion Potential (fossil)).
It should ﬁrst be noted that 10 EPDs for CTAs is a small number. As stated in the
introduction, in January 2023, there were about 16,000 third-party-veriﬁed EPDs for con-
struction products [
], which is not too much, especially considering the global dimen-
sion of construction and the variety of materials used. These data correspond well with
the number of scientiﬁc publications on EPDs, CTAs, and construction products. There-
fore, the result of the search in the Scopus database of scientiﬁc journals for the query
“EPD” + “construction products”
is the identiﬁcation of 2962 articles (Scopus database ac-
cessed on 10 March 2023). In the same study, only 13 articles were available for the query
“EPD” + “ceramic tile adhesive”. When the query concerned only “EPD”, 36,818 articles
were identiﬁed in the database. For the query “EPD” + “mortar”, the search identiﬁed
305 articles. The reason for the search with the word “mortar” was that CTAs are often
referred to as mortars, although they are a particular case of a large group of products
called mortars. CTAs are characterized by strictly deﬁned parameters and purposes in
EN 12004/ISO 13007-1. In the case of product A, analyzed in this article, which is a CTA,
its environmental impact data were calculated based on data for a broadly deﬁned group
referred to as mortars (repair mortars, adhesives, joint ﬁllers, screeds, ﬂoor leveling com-
pounds, grouts, and waterprooﬁng slurries), in which modiﬁed mineral mortars meet
criteria relevant for CTAs [
]. Additionally, for product K, the term “cement mortar for
tile installation” is used instead of CTA in the EPD. Santos et al., in a literature review on
the LCA of mortars published in 2021, also stated that there is a lack of quantiﬁcation of
mortar’s environmental impacts. However, more scientiﬁc papers on LCA and mortars
have since been published .
The analysis described in this article used data for CTAs from 10 EPDs, but only six
of them were valid at the time of the investigation, being the subject of this article. Of the
four EPDs that were no longer valid, three had expired in 2022, and one a year earlier, i.e.,
in 2021. It has not been identiﬁed that these documents have been amended, and their
validity has been extended, which is worth noting. This result may be surprising at ﬁrst,
because the number of EPDs issued for construction products is growing [
]. On the other
hand, there are claims that EPD owners are less interested in this document [49,88].
This lack of interest is due to various reasons, including the inability of the manufac-
turer to position its products among similar products to ﬁnd out whether it is comparatively
environmentally friendly [
]. This is important, because thinking about the environ-
mental impact of manufacturers as reducing negative impact has been formatted over the
Buildings 2023,13, 1326 8 of 17
]. Additionally, as noted by Dijkstra-Silva et al., “being “less bad” still means
harming the environment” [
]. For this reason, various authors point to the necessity and
importance of recognizing the positive impact of manufacturers on the environment [
All this indicates the need to develop new sustainable business models .
In addition, one should remember that the sustainability assessment of construction
products is still voluntary [
]. Additionally, one more important point to note. So far,
researchers who have extended responsibility for their work do not create the basis for
accurate decisions and policy formulation, but create for other researchers [
]. An analysis
of 1246 articles related to environmental labeling topics from over 22 years showed the
growth of theoretical considerations parallel to the development of environmental labeling
in the world .
The small number of EPDs for CTAs identiﬁed in this analysis and the fact that
as much as 40% of the EPDs analyzed in the article have expired, with no evidence of
their amendment and renewal, proves the existence of a crisis in this area. The situation
identiﬁed in the study regarding the decreasing number of valid EPDs for CTAs contradicts
the expectation of a higher demand for relevant data on construction products. It may also
prove that we are still not dealing with a signiﬁcant change in the approach and transition
from predominantly qualitative to predominantly quantitative assessment of construction
products, which manufacturers recommend .
Figure 1shows the analysis results of seven environmental impact indicators for
13 CTAs, which are listed in Table 2. Due to the different units in which individual
environmental indicators are expressed, and the essence of presenting them all in one
ﬁgure, Figure 1shows every single indicator as the quotient of the value of this indicator to
the lowest indicator value in a given group. Due to the signiﬁcant differences between the
analyzed values, a logarithmic scale was used to present the results, enabling data analysis
from a wide range.
Signiﬁcant differences exist between the values of all seven environmental impact
indicators in the range of modules A1–A3 of the analyzed CTAs. Minor discrepancies exist
for GWP, where the most signiﬁcant value for CTA marked as A is 2.69 times greater than
the smallest value for GWP for CTA marked as L. For ADP
, the value for CTA marked
as A is 4.25 times greater than that for CTA marked as F. The most signiﬁcant differences
were observed for ADP
and POCP indicators. For ADP
, the highest value (CTA-I) is
13.851 times higher than the value for CTA marked as D. Such signiﬁcant differences
between the values of environmental impact indicators between the analyzed CTAs prove
that it is impossible to make comparisons between products, which is a natural expectation
from all participants of the construction product market.
When analyzing the differences between CTAs’ environmental impact indicators and
trying to understand the state of affairs, various issues need to be considered. One im-
portant aspect is the type of binder, i.e., Portland cement, that is used to produce CTAs.
In the past, CEM I [
] was primarily or even exclusively used to make CTAs. Due to
the signiﬁcant environmental impact of cement production, a trend has been observed for
several years to increase the use of types of cement with a lower clinker content, i.e., CEM
II, CEM III, CEM IV, and CEM V instead of CEM I. The difference in environmental impact
between CEM II, III, IV, V, and CEM I is signiﬁcant. For example, the GWP for CEM I was
0.889 kg CO
eq., while for CEM II—0.704, CEM III—0.482, CEM IV—0.568, and CEM
V—0.518 kg CO
]. The above data were determined based on production data of
all cement plants in Poland from 2017, and the average environmental impact of types of
cement produced in Poland is slightly lower than the moderate environmental impact of
European types of cement .
Buildings 2023,13, 1326 9 of 17
Buildings 2023, 13, x FOR PEER REVIEW 9 of 17
Figure 1. Relative values of environmental impact indicators GWP (Global Warming Potential),
ODP (Ozone Depletion Potential), AP (Acidiﬁcation Potential), EP (Eutrophication Potential), POCP
(Photochemical Ozone Creation Potential), ADP
(Abiotic Depletion Potential (elements)), ADP
(Abiotic Depletion Potential (fossil)) for modules A1–A3 for the 13 analyzed CTAs marked with
leers from A to M.
When analyzing the diﬀerences between CTAs’ environmental impact indicators and
trying to understand the state of aﬀairs, various issues need to be considered. One im-
portant aspect is the type of binder, i.e., Portland cement, that is used to produce CTAs.
In the past, CEM I  was primarily or even exclusively used to make CTAs. Due to the
signiﬁcant environmental impact of cement production, a trend has been observed for
several years to increase the use of types of cement with a lower clinker content, i.e., CEM
II, CEM III, CEM IV, and CEM V instead of CEM I. The diﬀerence in environmental impact
between CEM II, III, IV, V, and CEM I is signiﬁcant. For example, the GWP for CEM I was
0.889 kg CO
eq., while for CEM II—0.704, CEM III—0.482, CEM IV—0.568, and CEM V—
0.518 kg CO
eq. . The above data were determined based on production data of all
cement plants in Poland from 2017, and the average environmental impact of types of
cement produced in Poland is slightly lower than the moderate environmental impact of
European types of cement .
In the EPDs analyzed in this article, apart from the CTAs marked as I and J, the type
of cement used for production was not disclosed, and the data for what kind of cement
was included in the calculations. In addition, it is worth noting that the data came from
diﬀerent years. Therefore, for the CTA marked as K, the data came from 2004, as indicated
in the declaration, which was published twelve years later in September 2016. Considering
that the cement content in CTAs is usually in the range of 30–40% by mass, this means a
signiﬁcant share in all environmental indicators. In addition, due to the substantial share
of the cement industry in global energy consumption and considerable carbon dioxide
emissions, the cement industry started actions to reduce its negative impact on the envi-
ronment much earlier than other branches of the economy, which today results in a much
Relative values of environmental impact indicators GWP (Global Warming Potential),
ODP (Ozone Depletion Potential), AP (Acidiﬁcation Potential), EP (Eutrophication Potential), POCP
(Photochemical Ozone Creation Potential), ADP
(Abiotic Depletion Potential (elements)), ADP
(Abiotic Depletion Potential (fossil)) for modules A1–A3 for the 13 analyzed CTAs marked with
letters from A to M.
In the EPDs analyzed in this article, apart from the CTAs marked as I and J, the
type of cement used for production was not disclosed, and the data for what kind of
cement was included in the calculations. In addition, it is worth noting that the data came
from different years. Therefore, for the CTA marked as K, the data came from 2004, as
indicated in the declaration, which was published twelve years later in September 2016.
Considering that the cement content in CTAs is usually in the range of 30–40% by mass,
this means a signiﬁcant share in all environmental indicators. In addition, due to the
substantial share of the cement industry in global energy consumption and considerable
carbon dioxide emissions, the cement industry started actions to reduce its negative impact
on the environment much earlier than other branches of the economy, which today results
in a much more considerable amount of environmental data. However, comparing existing
EPDs for cement shows differences as high as 300,000% between the highest and the lowest
reported value for ADP
]. In the case of the CTAs analyzed in the article, the differences
in this indicator were also huge—CTAs marked as D and E differed by 30% in the ADP
range for modules A1–A3, but the value for CTA marked as J was 8.220 times higher than
product D, and as much as 13.851 times higher ADP
value was recorded for product I
compared to product D.
When analyzing the values of CTAs’ environmental impact indicators, one should also
pay attention to the various cut-off criteria used in the LCA analyses, which are included
in the EPDs analyzed in this article. For example, for the CTAs marked F, G, H, and K, no
cut-off criteria were applied, and all reported data were incorporated [
]. For products
marked L and M, data for some raw materials were not found in the available databases.
Due to this, a contribution from those materials (less than 1% of the product mass) was
excluded from the calculation [
]. In the composition of CTAs, apart from cement and
Buildings 2023,13, 1326 10 of 17
ﬁllers, which comprise the majority of the product, there are ingredients of 0.3–0.4% of
the product mass, such as methylcellulose ethers. Often, data on these ingredients are not
included in the calculations. It should be remembered that, due to the high-energy process
by which methylcellulose ethers are obtained, and in how few places in the world they are
produced, which often means long transport to the location of their use for the production
of CTA, not taking into account their impact additionally reduces the credibility of the
obtained data. The use of different cut-off criteria is one of the factors that cause difﬁculties
when comparing products.
It is also worth noting that the use of secondary raw materials was invisible in this
study, which is vital for various reasons, including for the circular economy [92,95].
When evaluating each product, including a construction product, it is necessary to
determine the criterion whose fulﬁllment determines whether the product complies with
the requirements. In the case of construction products, the 3+ system proposed in the draft
CPR, which will apply to construction products assessed in terms of sustainability, states
that “the manufacturer shall carry out the assessment of the performance of the product
concerning essential characteristics or product requirements related to environmental
sustainability and keep it updated” [
]. In the proposed 3+ system, the notiﬁed body
shall, given input values, assumptions made, and compliance with appropriate generic or
product category-speciﬁc rules (i) verify the manufacturer’s initial and updated assessment,
and (ii) validate the process applied to generate that assessment [
]. Measurements or
calculations that are the basis for assessing each product must be reliable, and the variability
of the results resulting from uncertainty is an inherent part of the assessment process. It
is also the case with CTAs’ evaluation against the existing criteria [
]. The results of
this analysis should also be considered in this aspect. Among the seven environmental
impacts analyzed for the thirteen CTAs, the most negligible dispersion of results was
observed in the case of GWP and the largest in the case of ADP
. Thus, the mean value
for the thirteen analyzed CTAs for the GWP indicator is 4.34
the standard deviation from the analyzed sample is 1.23
eq. Thus, one
standard deviation, a classic measure of volatility, is 28% of the mean GWP’s value. For
, the mean value of the thirteen analyzed results is 1.52
kg Sb eq., and the
standard deviation is as much as 3.82
kg Sb eq., i.e., one standard deviation is
252% of the mean value. Signiﬁcant differences between the analyzed CTAs in the ADP
category are not particularly surprising, because the depletion of abiotic resources is the
most controversial environmental indicator subject to LCA [
]. The results presented in
this analysis and the literature on the EPDs also indicate that EPDs and the environmental
indicators contained therein are not analyzed in terms of uncertainty [99,100].
Rasmussen et al., analyzing 81 third-party-veriﬁed EPDs of cross-laminated timber,
glulam, laminated veneer lumber, and timber developed mainly in Europe but also in North
America, Australia, and New Zealand, proposed that life cycle assessment practitioners
can use median values from their study as the generic data [
]. In the case of CTAs,
in light of the data analyzed in this paper and considering the future potential AVCP of
these products, it should be stated that using mean values as generic data can lead to
As mentioned earlier, following the provisions of the CPR draft amendments, the
notiﬁed body should assess the manufacturer’s documentation in the ﬁeld of sustainability.
Questions arises about this veriﬁcation—how to relate it to the data collected over a
decade? Is it possible? Based on the data presented in this analysis, there is only one
answer—unfortunately, it is impossible.
The draft amendment to the CPR assumes that the producer will systematically update
environmental indicators. Currently, third-party-veriﬁed EPDs are primarily valid for ﬁve
years. Additionally, for this reason, the situation will create a ﬁeld for conﬂict between
producers. Comparing data from this year with data from ﬁve years ago will pose problems.
The data for CTAs collected in Table 2does not clearly show the changing trend related to
the passage of time. However, for other construction products, where the data associated
Buildings 2023,13, 1326 11 of 17
with the production of the same product by the same manufacturer at the exact production
locations in different years, differences were reported [
]. This critical observation about
change over time is consistent with the fact that, in the current model, the assessment
concerns the “static” manner, but the world is changing dynamically .
Another issue regarding the future assessment of construction products in terms
of sustainability is the human resources of the notiﬁed body. Of course, this issue is
known and discussed in the literature [
]. As mentioned many times, the inconsistency
between published EPDs is known. The fact that years have passed and this issue remains
unresolved is also a sign of the lack of availability of properly educated specialists.
The introduction of a mandatory 3+ system in the ﬁeld of sustainability, however justi-
ﬁed, also generates additional costs. These costs may be difﬁcult for smaller entrepreneurs
to cover. In the case of smaller producers, there will also be a problem with access to
suitably qualiﬁed staff. Additionally, from this perspective, the question arises about the
legitimacy and sense of the proposed formula for assessing construction products in the
ﬁeld of sustainability. In this connection, there is the already raised issue of the possible
role of associations of producers [33,34].
A view can also be formulated that, due to the lack of comparability of EPDs, it is
difﬁcult to talk about public trust in the issue of proper assessment of construction products
in terms of sustainability. However, public trust is fundamental in building matters [
Research on the conscious consumption of such construction products as interior wall paints
and coatings showed a higher importance of making environmental assessment transparent
to end-users [
]. It is also crucial in terms of the fact that consumers today do not have
the willingness to pay the premium price for sustainable products [
all this must be considered by the manufacturer when creating a strategy promoting
environmentally friendly products. This is not easy, although, from the perspective of
science, there are views that it is a business opportunity [
]. Of course, it can be, but it
has to be based on solid foundations, including consistent and comparable data from EPDs.
As the study results described in this article show, data on the environmental impact of
CTAs do not make it easier for construction market participants to make the right decisions
when choosing a product. Additionally, considering that other research referring only to
the knowledge of the role of EPDs in the environment of people professionally related
to the construction industry showed that as many as 75.9% of the surveyed sellers of
construction products and 74.0% of investors, as well as 64.6% of contractors, believe that
EPDs are a mandatory document, but in fact they are voluntary documents [
in the professional group of architects did a minority of respondents (43.5%) consider
the EPD a required by-law document [
]. Although these answers are incorrect, they
indicate that sustainability issues are perceived as signiﬁcant. In the same study, the share
of people considering the environmental impact (by a declarative “yes” or “no”) when
selecting construction products varies from 39.1% in the group of architects to 59.8% in
the group of investors [
]. However, to another question that only required a “yes” or
“no” answer, i.e., the question of knowing the GWP value of 1 m
of External Thermal
Insulation Composite System, responses of “yes” ranged from between 27.1% and 49.7%
in the surveyed groups of professionals [
]. Other studies, in which 55 respondents
gave answers regarding use of EPDs by architects, showed as many as 76% declare their
]. Above all, however, it is worth mentioning that the results of the examination of
sustainability knowledge to understand sustainable behavior indicated that knowledge
had a signiﬁcant, albeit weak, bivariate correlation with behavior .
It is also important to mention that, although CTAs belong to the mortars group
and are perceived and classiﬁed in this way in many studies, which is also visible in the
EPDs analyzed in this article, they are a group of specialist construction products. For
this reason, environmental impacts related to the production of CTAs cannot be consid-
ered at the general level of the relationship between mortars and sustainability, treating
mortars as a mixture of three components: aggregates, binders, and water [
are produced in specialized dry-mix mortar plants. Thus, modules A1–A3 can be or are
Buildings 2023,13, 1326 12 of 17
based on existing or historical data, so it is possible to estimate the impacts in principle.
However, it should be remembered that the given value of environmental indicators in
the declaration of performance of construction products will always be only an approxi-
The analysis presented in this article is a contribution to knowledge transfer from
industry to science. The ﬂow of knowledge from industry to science is often the missing
link for properly developing a topic. Of course, issues such as those discussed in this
article, such as the unclear and sometimes confusing values of environmental indicators,
reliability of LCA, LCA input data availability, the necessity of harmonization, inadequate
legislative framework, and necessity of coherence of EPDs, are the subject of scientiﬁc
research and publications [
]. However, still, the producers’ point of view is rarely
taken into account. However, due to the plans to amend the CPR and introduce a new
3+ conformity assessment system, it is necessary to consider the manufacturers’ position.
Otherwise, further development of construction products will be disturbed, including the
dissemination of information on the environmental impact of the product. Finally, it is
reasonable to write that the conclusions drawn from the analysis described in this paper
are consistent with the recently formulated recommendations .
However, to the author’s knowledge, no analysis has been published on the conse-
quences of introducing a mandatory CTA environmental impact assessment in the event of
the CPR amendment. Results clearly show that notiﬁed bodies are not prepared to verify
EPDs, along with a signiﬁcant increase in their number due to the introduction of the
obligatory sustainability assessment of construction products.
This study analyzed the values of seven environmental impact indicators of thirteen
CTAs. The author discussed speciﬁc conditions related to the assessment of a construction
product, which has not been a subject of particular interest so far, such as the issue of
uncertainty. The work indicates many factors inﬂuencing this state of affairs:
The analysis of the values of seven environmental impact indicators (GWP, ODP, AP,
EP, POCP, ADP
) showed signiﬁcant differences between them, the smallest
being for GWP and the largest for ADPe;
The difference between the lowest and highest value of the GWP indicator amounted
to almost 270%;
The difference of nearly fourteen thousand times between the lowest and highest
value of the ADPeindicator make it impossible to compare CTAs;
The analysis described in this article clearly shows that the planned introduction of the
environmental assessment of construction products has not been properly prepared.
The results obtained over a decade on the environmental impact of CTAs may be of
little use for the future assessment of these products. In addition, it should be noted
that due to permanently going on a benchmark that takes place on the market of
construction products, many manufacturers may practice greenwashing to show that
their products are not “worse” than others.
6. Future Directions and Limitations
The analysis showed that the environmental impacts of CTAs collected over a decade
are inconsistent, and their use in AVCP does not help consumers choose products. It is
necessary to specify the requirements for qualitative data used in LCA precisely, understood
as narrowing the boundaries, e.g., to data from one year preceding the year of EPDs creation.
In light of the obtained results of the analysis and considering other experiences gained
over the decade, it seems reasonable to develop product category rules used in developing
EPD by producer organizations at the local/national level. It appears that the participation
of producer organizations should facilitate the creation of a transparent situation for all
participants in the construction products market.
Buildings 2023,13, 1326 13 of 17
The analysis described in this paper concerned data for 13 CTAs presented in 10
EPDs, i.e., on a relatively limited sample. As mentioned earlier, sixteen thousand EPDs
were published in January 2023 for construction products in general, which is also not
a representative number for the construction products market. Undoubtedly, one of the
reasons why CTA producers do not develop EPDs en masse is that the results contained
therein are not easily presented to consumers. Above all, it should be remembered that
EPDs are voluntary documents, which is also the reason for their limited number.
Funding: This research received no external funding.
Data Availability Statement: Not applicable.
Conﬂicts of Interest: The author declares no conﬂict of interest.
ADPeAbiotic Depletion Potential (elements)
ADPff Abiotic Depletion Potential (fossil)
AP Acidiﬁcation Potential
AVCP Assessment and Veriﬁcation of Constancy of Performance
CPR Construction Products Regulation
CTA Ceramic Tile Adhesive
EP Eutrophication Potential
EPD Environmental Product Declaration
GWP Global Warming Potential
LCA Life Cycle Analysis
ODP Ozone Depletion Potential
PCR Product Category Rule
PEF Product Environmental Footprint
POCP Photochemical Ozone Creation Potential
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