Laws and Regulations

Product Environmental Footprint Methodology

01 June 2021

TrusTrace Sustainability team

This text is a methodology, its implementation will be determined by other decrees and acts. This methodology is not 100% agreed on yet, more details will come.



What does it mean?

The Product Environmental Footprint (PEF) is a LCA* based approach to quantify the environmental impacts of goods or services. It is developed by the European Commission with the goal of harmonising and improving the quality of the sustainability information shared with the consumers and thus encouraging the consumption and production of sustainable products on the EU Single Market.  

The PEF methodology will define how to calculate and communicate an environmental score for a product. Different methodologies will be defined to adapt to the specificities of different product categories. As PEF is a LCA, its aim is to cover the entire life-cycle of a product.  

The PEF methodology does not define yet the scope of its application, when the methodology will be ready, it will first be voluntary, but it is very likely that future decrees from the Commission will make PEF scoring mandatory for some product categories. As textile is one of the most impactful sectors, it is very likely that it will become mandatory these products. Also, as a EU Member State, France is pushing towards that goal by adopting in 2021 a law that will make environmental labelling mandatory for fashion products. An alignment between EU and France is likely to happen on that level.  

* LCA = Life cycle assessment. It is the factual analysis of a product’s life cycle from a sustainability and environmental impact point of view. The product life cycle is composed of 5 phases : extraction of materials, manufacturing, distribution, use and disposal. The goal of making an LCA is to measure the environmental impact of a product from cradle to grave.   

Who is impacted? 

Ultimately, PEF will impact all companies putting goods on the EU market.  If we look at fashion, the PEF methodology for apparel and footwear will become the reference method to assess the environmental impacts of their products and to substantiate their sustainability claims.  


Content & Implementation

PEF Category Rules (PEFCR)

The PEF Category Rules (PEFCR) is a set of specific rules or standards created for different product groups. In other words, it is a technical guidance document that will specify how to conduct PEF for a product. 

In order to ensure comparability, the EC wanted to establish specific rules for different product groups as single criteria and boundary conditions can’t be used for all. For example, we cannot compare beer production to paper production and hence it is important to set guidelines for different product groups. PEF guide and PEFCR document can be used for comparison of the environmental performance of different products from the same product category on a life-cycle basis.   

Product Environmental Footprint – Timeline 

PEF is in the transition stage right now. The EC is evaluating where PEFCR methodology can be used and implemented. The EC has not specified the period of implementation, but the industry experts are expecting it to get implemented sometime next year or by 2024. 

The policy development is not yet completed or defined fully, but PEF will have an impact on business as there is an increased demand for environmental transparency from the consumers, especially with respect to supply chain risks. 



How does PEF differ from LCA? 

  • The system boundaries are well defined in PEF where the entire product’s life cycle (cradle to gate) is taken into calculating the footprint.  Whereas the boundary conditions in LCA are subjective, and depend on the reporting company. 

  • The methodology in PEF is clearly defined and can be compared.  

  • PEF has laid out methodology for end-of-life of products, whereas, in LCA it has always been optional. 

  • With PEFCR, PEF has better chances for reproducibility, and consistency.



As the regulation is not implemented yet, the consequences are not clearly laid out. Generally speaking, companies preparing themselves for this regulation will surely have the first mover advantage especially when it comes to communicating the footprint to the consumers.  


Please note: At TrusTrace, we want to keep you informed on laws and regulations, but this information should not be considered or used as legal advice.

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