Julie Brown
Head of Sustainability, EON
March 28, 2023

All you need to know about Product Environmental Footprint

EON's Head of Sustainability shares an inside look at the EU's Product Environmental Footprint (PEF) legislation.

Consumers are demanding clearer and more consistent information about their apparel products. 59% think that product labels don’t provide enough information, and 48% think that labels are not clear.[1] To help address this issue, the European Commission initiated the Single Market for Green Products Initiative in 2013 to facilitate better information on the environmental performance of products and organizations. It proposed the Product Environmental Footprint (PEF) as a common, life cycle assessment (LCA) based approach to measure the environmental impacts of all products.

The same methodology can’t be used for all products because boundary conditions and assessment criteria differ greatly between industries. For example, the rules that apply to footwear won’t be relevant for household detergents. Therefore, a different set of rules must be defined for different product groups. This set of rules is called a Product Environmental Footprint Category Rule (PEFCR) and ensures that products within that category will be measured in a common way, making the results comparable between products.

The PEFCRs are still being finalized, but we know that specific requirements for all background data will be set, and there will be a central database to minimize the differences that often occur in LCAs due to modeling decisions. We also know the assessment must measure the full lifecycle of a product against these impact areas:

  • Climate Change
  • Ozone Depletion
  • Ecotoxicity for aquatic fresh water
  • Human Toxicity - cancer effects
  • Human Toxicity - non-cancer effects
  • Particulate Matter/Respiratory Inorganics
  • Ionising Radiation - human health effects
  • Photochemical Ozone Formation
  • Acidification
  • Eutrophication - terrestrial
  • Eutrophication - aquatic
  • Resource Depletion - water
  • Resource Depletion - mineral, fossil
  • Land Transformation

The PEF is likely to affect all companies putting goods on the EU market. The European Commission is currently evaluating PEFCR methodology and has not specified a date for implementation. However, industry experts suggest it could be implemented as early as 2024. It will largely be voluntary at first, but the Commission may make PEF scoring mandatory for some product categories in the future. Simultaneously, France’s Climate and Resilience Law will require environmental labeling on all products sold in France beginning in 2024. It is likely that PEF methodology will be leveraged in this French regulation. Additionally, the Ecodesign for Sustainable Product Regulation is defining information requirements on Digital Product Passports in 2024. It is reasonable to think that these requirements will include environmental impacts of products and are to be calculated using PEF methodology.

A closer look at apparel and footwear[2]

In 2020 a Technical Secretariat (TS) began to develop the methodology for apparel and footwear. This TS is comprised of representatives of various stakeholders including brands (about 50% of the European market) from the textile sectors, NGOs, scientific experts, and governments. These experts drafted an Apparel and Footwear PEFCR that has undergone one round of public consultation and been tested in supporting studies. A second public consultation is taking place this year, and in 2024 the final methodology will be presented to the European Commission for approval.

The Apparel and Footwear PEFCR defines specific rules tailored to 13 apparel and footwear sub-categories:

  • T-Shirts
  • Shirts and Blouses
  • Sweaters and Mid-Layers
  • Jackets and Coats
  • Pants and Shorts
  • Dresses, Skirts, and Jumpsuits
  • Leggings, Stockings, Tights, and Socks
  • Underwear
  • Swimwear
  • Apparel Accessories
  • Open-Toes Shoes
  • Close-Toed Shoes
  • Boots

While the PEFCR generally follows common LCA principles, it incorporates creative assessment methods to cover environmental factors not usually assessed in LCAs that are particularly important for apparel and footwear. These factors include circularity (recycled content and recyclability), durability (number of times a product can be worn), and repairability (capacity to be repaired to extend the lifetime of a product). The PEF methodology will continue to evolve to include additional factors such as microplastic release as scientific data and evidence are made available.

The TS is requiring primary data for the most relevant stages of the lifecycle, while secondary data (provided in a central database) may be used for less relevant stages. Proposed primary data requirements include the following:

  • Raw materials: Those most critical stages include raw material production by type and quantity per bill of material, raw materials transport (distance, mode, mass), Manufacturing: processes and technologies used, specific location, and loss rates
  • Distribution: air cargo distance if more than 50% greater than a default distance provided.
  • Other: Final product weight, deadstock rate and fate

Numbers snapshot


of consumers think that product labels don’t provide enough information


of consumers think that labeling should provide environmental and fair labor information


of consumers think that labeling should provide environmental and fair labor information

Kantar, 2019
EON - providing greater transparency and accuracy

When PEF is implemented, environmental impacts of products will be available and may be communicated to the public. Consumers will be better informed about the environmental impacts of products at the time of purchase which will allow them to make more informed decisions. However, once the product is purchased, it is no longer connected from that impact information. EON can ensure that a product’s PEF results remain with a product throughout its full lifecycle – accessed via a Digital ID – even after the point-of-sale, providing a longer return on investment in conducting the assessment that can be seen by multiple owners. Then the score is no longer influencing one person, but many. The data stored on a product’s digital ID can also help companies compare their product longevity to industry assumptions, provide insights regarding their product quality and perhaps even influence PEF methodology to update product lifetime assumptions in the future. This will not only improve the accuracy of the assessment and subsequent score, but provide a greater return on investment in repair, reuse (e.g. resale), and recycling programs.

[1] https://ec.europa.eu/environment/eussd/smgp/index.htm

[2] Note This section reflects the draft of the PEFCR. The methodology and requirements are not final until approval in 2024.





Ready to unlock the potential of your products?

Explore the EON Product Cloud platform.

More News