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What is Product Environmental Footprint (PEF), and what do you need to know about it?

November 10, 2022
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Product Environmental Footprint (PEF): What it is and what it means for fashion brands.

With upcoming regulations such as the New York Fashion Act and the 2026 EU Regulations set to crack down on the sustainability claims made by fashion brands, proactive brands are gearing up to conduct more comprehensive evaluations of the environmental impacts of their products.

But it’s tough to know where to start: which methodologies should you use? What should you disclose to the public? And on the consumer side, it’s difficult to evaluate the relative impacts of products on the market when every brand discloses this impact in unique ways.

Fortunately, the European Commission is about to make this process easier for brands and consumers alike with the release of their Product Environmental Footprint (PEF) methodology within the European Union Single Market for Green Products Initiative. PEF methodology will provide brands and consumers with comprehensive and universal standards with which to evaluate the impact of their products.

In this article, we explore PEF in detail, including its foundation in LCAs (life cycle assessments), and what it could mean for apparel brands and the industry at large.

What is Product Environmental Footprint (PEF)?

Product Environmental Footprint (PEF) is a methodology for calculating the environmental impact of a product over its lifetime. Although PEF has been proposed by the EU commission as part of its Single Market for Green Products Initiative, it is a methodology, not a piece of legislation in its own right.

PEF is based on life cycle assessment (LCA) methodology.

What is a life cycle assessment (LCA)?

Life cycle assessment (LCA) is a methodology for calculating a product’s environmental impact. LCAs are widely used in the apparel industry, as they provide a clear picture of the materials that make up a product, and how these materials impact the environment at every stage of a product’s life — from raw material extraction to manufacturing, distribution, usage, and all the way through to disposal.

Recently, LCAs have been criticized for their credibility, which can be a problem when quality data and expertise is lacking. But as our Chief Sustainability Officer (and the foremost expert in textile LCA in the world), Dr. Subramanian Senthilkannan Muthu, explains, “The LCA process generates the best means for companies and customers to make quality decisions on reducing our impact. Like any other solution, it is not perfect, but requires nuanced discussion; tossing industries wholesale under the bus via headlines which are more attention-grabbing than informative is deeply damaging.”

What’s the difference between LCA and PEF?

To put it simply, PEF is based on LCA, and both are methodologies for calculating the impact of a product over its lifetime. The PEF, which proposed by the EU Commission, is more clearly defined than the universal LCA methodology, and will essentially become the ‘gold standard’ for LCAs in Europe.

For example, PEF defines clear system boundaries for product lifecycles, whereas LCA boundaries are open to interpretation. PEF also provides rigorous guidance for assessing end-of-life, but LCA does not require this. PEF is standardized for comparability between products, whereas the scope of an LCA can differ depending on who is conducting the assessment. But comparability is only possible if the results are based on the same rules, which is why the PEFCR exists.

PEFCR are PEF’s ‘Category Rules’ for individual product groups, which offer step-by-step guidance on conducing PEF for each kind of product. For the apparel sector, the EU Commission engaged the Sustainable Apparel Coalition (SAC) to develop Global Apparel and Footwear (PEFCR), serving as a policy standard for EU clothing and footwear products. These category rules (referred to as PEFCR) make PEF ideal for achieving consistent and comparable environmental impact reports across the apparel industry, ensuring that every product’s impact is calculated to the same standards and that consumers can compare ‘apples to apples’, or cotton t-shirts to cotton t-shirts.

What are the benefits of PEF for the fashion industry?

Mandating a standardized methodology will help guide brands through the process of assessing and disclosing the environmental impact of each of their products. It will also help consumers accurately compare available products and ensure that the sustainability claims and labels produced by brands are accurate and credible.

Additionally, as more brands conduct accurate assessments of their product impact, they will spot more opportunities to produce more sustainable products. At the same time, an assurance of quality data and credible claims will encourage consumers to purchase available eco-friendly products, driving the entire industry forward as a result.

A brief timeline of PEF

The EU Commission indirectly confirmed its intention to pursue implementing PEF at the end of 2021, when it accepted a revised recommendation on PEF usage. Currently, the PEF is undergoing evaluation by the EU Commission; the implementation date is currently unknown but could be sometime in 2023 or 2024. We encourage brands not to wait: smart brands will start preparing to conduct PEF assessments now, so as to be fully prepared when the time does come.

What are PEF’s implications for apparel brands?

PEF requirements will impact apparel brands trading in Europe, although the precise impacts are yet to be known.


Even without knowing when and how PEF methodology will become required practice for apparel brands, the evidence is clear that proper product impact assessments such as LCAs bring a multitude of benefits. They offer a quantitative basis for sustainability strategies, which can help a brand uncover hotspots for improving product design and make tactical sustainability decisions.

Accurate assessments of product impact help companies to uncover the relative impact of various materials within their supply chains, research alternative materials for their products, make more informed procurement decisions, and work collaboratively with suppliers on planet-positive R&D.

And finally, access to credible product impact data only bolsters sustainability claims, improving trust among consumers and stakeholders, and protecting your company against accusations of greenwashing.

As I have been saying for over a decade,” says Dr. Subramanian Senthilkannan Muthu, “LCA [and thus, PEF] is the future and it is our responsibility to foster its growth. Quality is always a key concern in any LCA report, and all LCA practitioners should strive to deliver credible, transparent reports.”


Regulation has not come into force yet, which means there are still unknowns for appeal brands, including potential punitive consequences for brands who fail to comply with PEF requirements. But the more your brand can begin to quantify and assess the environmental impact of its products ahead of time, implement more robust data collection measures, and make strategic sustainability decisions, the more prepared your company will be when legislation is instituted.

Green Story can help

At Green Story, our mission is to empower 1 billion consumers to know their impact and make choices that are better for the planet and the generations to come. We’ll help you quantify and visualize your environmental impact, make accurate claims about the sustainability of your products, and offset your emissions through verified carbon credits. We’ll also make sure your customers are along for the journey by telling your sustainability story in ways your consumers can easily grasp, integrating your story into every aspect of your communications, and achieving market-wide buy-in for your sustainability mission.

About Amelia Zimmerman

Amelia Zimmerman is an ESG and sustainability writer. She lives in Toronto with her puppy and her partner, and she is passionate about using storytelling techniques to help people understand and act on climate change.