PEF for Apparel and Footwear: The EU’s Product Environmental Footprint Methodology

Since its introduction in 2019, the European Green Deal continues to roll out new legislative initiatives designed to transform the EU into the first climate-neutral continent by 2050. A myriad of technical methodologies and tools have been introduced to reach this goal, one of which is the Product Environmental Footprint (PEF), a methodology for Life-Cycle Assessments (LCA).

On its own, an LCA is a very broad methodology for assessing the environmental impact of products. As such, the PEF method was developed to serve as a common language for LCAs, standardizing how the environmental performance of products is measured, communicated, and improved across the continent. One of the biggest challenges the PEF method will tackle is greenwashing claims.

Housed within the PEF method are PEF Category Rules (PEFCR), designed to provide more specific guidelines for individual product categories. The Apparel & Footwear PEFCR is currently in development and is scheduled to launch in Q4 of 2024. The dynamic and technical nature of these emergent frameworks is a lot to digest. That’s why we’re taking a deep-dive into the European PEF and how fashion and textile brands can prepare.

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What is the PEF methodology?

The European Product Environmental Footprint (PEF) method is a comprehensive framework designed to evaluate the environmental performance of products throughout their entire life cycle—from raw material extraction, manufacturing, and distribution to usage and end-of-life disposal. Think of a PEF study as an LCA study that uses a specific and consistent set of guidelines.

The PEF Guide was first introduced in 2013 and later revised in December 2021. The initiative arose from an acute awareness that the environmental impact of products needed to be measured and communicated in a more consistent and transparent manner across the European Union.

Apparel & Footwear PEFCR

The Apparel & Footwear PEFCR is being developed by a multi-stakeholder group known as the Technical Secretariat. While there has been criticism over its composition during different consultation rounds, where stakeholders could share their feedback —primarily large apparel and footwear brands—the final review and approval of the rules will be conducted by independent experts and EU representatives.

The Technical Secretariat has the difficult task of analyzing a complex industry and creating a set of rules that are both accessible to fashion brands of all sizes and precise enough to generate comprehensive PEF studies. No set of standardized environmental impact methodology has ever been developed. To create the PEFCR, the Technical Secretariat is taking into account the following factors:

Circularity – including the use of recycled materials and if they're able to be recycled after use.
Durability – assessing how many times a product can be worn on average. This is an interesting factor, as durability must refer to both the emotional (how many times a person wants to wear a garment) and its physical (the actual lifespan of the product) longevity.
Repairability – gauging the capacity of a product to be repaired, thus extending its lifespan.

The Apparel and Footwear PEFCR will be all-inclusive, covering every category of garments and footwear. The Technical Secretariat has broken this down into 13 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-toed shoes
Closed-toe shoes
Boots

While this list may seem detailed at first blush, there exists a multitude of unique product uses within each sub-category. For example, a heeled leather boot will have different durability and repairability requirements than a mountaineering boot. This presents the PEFCR method designers with the additional challenge of creating meaningful performance indicators that allow for a true comparison of sustainability.

The Technical Secretariat is also open about the environmental impact factors not currently included in the initial PEFCR. To date, the PEFCR does not fully address microplastic pollution or biodiversity. The group is also currently awaiting guidance on second-hand labeling to tease out the number of uses a garment can be worn by both the first user and those thereafter.^[i]

What’s included in the PEFCR scope?

As you’ve probably gathered by now, the PEFCR is a highly technical framework, developed by and for LCA experts. There’s a lot to digest within the scope of the PEFCR, so we’re highlighting the key elements that fashion brands should be aware of.

Let's start with the 16 impact categories to understand which environmental factors must be considered in a PEF study. You’ll notice these categories extend beyond the impacts of climate change. The scope of the PEFCR is key to tracking all forms of environmental impacts, avoiding what many call “carbon tunnel vision.” (You can read more about the correlation of different environmental indicators in this blog by our co-founder Martin Daniel.)

Transparency is key in this process, and the EF 3.1 reference package provides a detailed list for ensuring clear and consistent evaluation. While the PEFCR is still in draft mode, it is expected to encompass the following impact categories:

Climate change: encompasses all inputs and outputs associated with greenhouse gas emissions. This includes sub-categories such as fossil fuel and land use.
Ozone depletion: includes the assessment of stratospheric ozone depletion caused by emissions of ozone-depleting substances, such as long-lived chlorine and bromine-containing gases (e.g., CFCs, HCFCs, Halons).
Human toxicity - cancer: evaluates the potential health impacts on humans related to cancer from exposure to toxic substances.
Human toxicity - non-cancer: covers potential health impacts related to non-cancer effects from exposure to toxic substances.
Particulate matter: assesses the health impacts caused by inhalation of fine particulate matter and other air pollutants.
Ionizing Radiation – Human Health: measures the effects of ionizing radiation on human health.
Photochemical Ozone Formation: evaluates the formation of ground-level ozone (smog) and its impact on human health.
Acidification: assesses the impacts of acidifying emissions, such as ammonia and nitrogen dioxide, on soil, water bodies, and ecosystems.
Eutrophication – terrestrial: relates to the impact of nutrient enrichment on terrestrial ecosystems.
Eutrophication – aquatic: covers the impact of nutrient enrichment on freshwater and marine ecosystems.
Ecotoxicity – freshwater: assesses the toxic effects of chemical emissions on freshwater ecosystems.
Land Use: evaluates the impacts of land occupation and transformation on biodiversity and ecosystem services.
Water Use: measures the potential environmental impacts of water consumption and depletion.
Resource Use – fossil fuels: assesses the use and depletion of non-renewable fossil resources like oil, coal, and natural gas.
Resource Use – minerals and metals: assesses the use and depletion of non-renewable mineral and metal resources.
Ionizing Radiation – ecosystems: measures the effects of ionizing radiation on ecosystems and non-human species.

PEF indicators

Each of your products will have an individual PEF score, as well as some high-level information about how it was calculated. Each of the above impact categories will contribute a percentage to a product’s score. For instance, climate change has the highest weight, contributing 21% to the overall score, with the remaining percentages allocated to other impact categories.

PEF score (3) PEF score in Carbonfact - Sustainability platform

A lower PEF score indicates a product with a reduced environmental impact. By integrating 16 different impact indicators into a single score, the PEF score offers a straightforward way for consumers to understand and compare the environmental impacts of products within the same category.

As we've seen above, the PEF details 16 impact categories that are then aggregated into a measured PEF score. To see this in practice, check out the table below. Here, we can examine how the environmental indicator, unit, and weight are used to create the PEF score.

PEF indicators (2) 13 of the 16 environmental indicators from the PEFCR listed by Ecobalyse. See more details here.

PEF terminology

As mentioned, the PEFCR is the first comprehensive attempt to lay out criteria for assessing environmental impacts within the fashion industry. Many of the mechanisms for doing so will be new for brands, so we’re highlighting a key terminology below:

Functional Unit (FU): Defined as the quantified performance of a product system, the FU for A&F PEFCR is uniquely tailored to gauge the ability of a product to meet the consumer's needs in good condition for one day of wear. This approach, diverging from traditional metrics such as 'one garment' or 'one kg of garments,' underscores the significance of durability in environmental sustainability.

^[ii]Representative Products: Embodying the “market average” in terms of environmental performance, these products will utilize industry-average data or primary data from contributing members of the Technical Secretariat. The representative product's average performance and impacts will be calculated, serving as a benchmark for evaluating the environmental footprint of similar products in the market.

Lifecycle Inventory: A comprehensive dataset or document containing specific life cycle information about a product, site, or process, which includes both descriptive metadata and quantitative inventory data. An LCI dataset may range from a detailed unit process dataset to a partially or fully aggregated dataset.

Lifecycle Stages: Breaks down the lifecycle of a product, from cradle-to-grave, into a series of stages. This includes:

LCS1 – Raw materials acquisition and pre-processing
LCS2 – Manufacturing
LCS3 – Distribution
LCS4 – Customer use
LCS5 – End of life

Verification: There are baseline verification requirements consistent across all PEFCRs, encompassing both the scope of verification tasks and the qualifications required of the verifier. Individual PEFCRs may have further guidelines, but none have yet to be established for Apparel & Footwear.^[iii]

Primary data and secondary datasets

To calculate the environmental impact of a single garment, a lot of data points are required. Fashion brands will need to source both primary and secondary data to conduct a PEF study.

Primary data is derived directly from your company’s business operations and supply chain.

Unlike other types of life cycle analyses, a PEF study actually requires certain data points to be collected directly from the suppliers as a means to standardize the reporting from company to company. These data points will likely include:

Raw material production and type and weight per unit of material including trims and material provenance.
- Example: composition, origin or production steps, etc.
Raw materials transport
- Example: mass transported, mode of transportation, distance traveled for each material
Manufacturing: processes and technologies used
- Example: spinning, weaving, dye cutting, sewing, assembly, etc), specific location, and loss rates.
Final product weight, deadstock rate, and deadstock fate.

Due to the intricate, multi-layered nature of their supply chains, where many of the actors are not directly in contact with each other, it is not always possible or even necessary to collect primary data about every process from a time and resource perspective. This is when secondary data comes into play. Secondary data is generic life cycle inventory data aiming to represent the industry average processes. This type of data is used in PEF studies when primary data cannot be collected or when the PEFCR dictates its use to ensure comparability of the different assessments.

In 2022, the European Commission released a secondary dataset—known as EF 3.1—which contains detailed secondary data for apparel and footwear that companies may use. Via the database Ecoinvent, companies can utilize these datasets to ensure consistency and reliability in their environmental impact assessments, allowing for accurate comparisons and regulatory compliance across the industry.

The PEF method follows the “materiality principle” – which means focusing only on what matters most and applying secondary data for the rest. For their PEF studies, companies will have to select the most appropriate dataset from the EF database based on their primary data. For example, brands should select the best cotton dataset to reflect the origin and yarn size used in their products. For the rest, the default data provided in the PEFCR can be used, for example, to model the distribution pathway for a typical dress. Fashion brands can also create new EF-compliant datasets fully based on primary data.

Read how Carbonfact applies this principle with Supply Chain Blueprints.

PEFCR limitations

As we’ve indicated above, there remain certain limitations to the PEFCR, such as impact areas that are not currently covered. That’s why it’s best considered an evolving document that will address some of these challenges in the future. Among these missing categories are microplastics, chemical exposure, biodiversity, and social impacts.

While microplastics are a growing concern, there is currently no standardized methodology for measuring their impact on human or environmental health. For example, we are not yet aware of a “planetary threshold” for microplastics (as there is for GHG emissions). While microplastic shedding from popular garments such as fleece is a concern for many brands, it’s still a challenging metric to track.

Similarly, adding biodiversity as an impact category is problematic because it functions as an endpoint indicator, reflecting final outcomes, whereas existing PEF impact categories are mid-point indicators that represent contributing factors. This fundamental difference complicates the integration of biodiversity into the PEF method, making it difficult to develop a comprehensive and meaningful assessment.

For the fashion and textile industries, chemical exposure is a significant concern given the ongoing use of toxic chemicals like PFAs in textile production. While the UseTox methodology effectively measures toxicity in life cycle assessments, it does not account for direct human exposure through skin contact or inhalation of fibers.

Lastly, the PEFCR does not yet have a direct measurement for social impacts or animal welfare/exploitation. There are currently international guidelines in development for child labor, modern slavery, and the livelihood of farmers. Because these types of social impacts are fairly black and white, some argue that they are best addressed via strict legislation rather than the PEFCR. On the other hand, the issue of animal welfare and exploitation proves to be a trickier subject to find a consensus on, largely because there is no standard methodology for tracking the impacts on animals raised for their by-products.

Apparel & Footwear PEFCR status and timeline

The Apparel and Footwear PEFCR is currently in the implementation phase. This means that the methodology is currently tested on real products by companies, and the methodology is further being developed based on the feedback throughout 2023 and 2024. The PEFCR is scheduled to be officially adopted in 2025 by the European Commission, which then can be used for future legislation. Brands and the industry will then be required to use this common framework to assess the environmental footprint of their products.

Since the first draft was launched in 2019, the Technical Secretariat has conducted a number of public consultations and supporting studies. As of the time of writing, the group is still on track to release PEFCR recommendations to the European Commission.

PEFCR and EU textile regulations

PEFCRs have the potential to be utilized across a range of regulatory or private initiatives. Because of their role in standardizing and clarifying reporting metrics, they will likely be adopted by European legislation such as the Ecodesign for Sustainable Products Regulation (ESPR), the Digital Product Passport (DPP), Green Claims Directive and Empowering Consumers in the Green Transition Directive, and Corporate Sustainability Reporting Directive (CSRD).

How can Carbonfact help?

Carbonfact is an environmental sustainability software, built for apparel and footwear. We know that measuring a garment’s environmental footprint is a complex task. Manually gathering, and consolidating data across the outsourced manufacturing and own business is not only error-prone but also unsustainable as new laws increase reporting requirements.

Our software addresses the fashion industry's challenge of collecting data, calculating product environmental footprints, and reporting in line with the upcoming textile regulations.

Carbonfact automates this time and resource-intensive task, we connect to the IT systems, and then clean and analyze the data to identify primary gaps and anomalies. We then systematically fill in any missing details with the EF 3.1 data and provide reliable footprint calculations, in line with the PEFCR. On the live platform, brands can see their PEF score, identify emission-intensive manufacturing processes, build reduction plans and export automatically created reports for annual carbon disclosure.

To calculate product emissions Carbonfact employs a comprehensive carbon footprint model that encompasses all production stages, from sourcing to finishing and assembly of purchased products. The foundation of the product LCA model Carbonfact developed is based on the latest draft of the Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear.

See how it works in the demo video: