You Ask, We Answer - PEFCR v3.1 (30 Questions Answered)

"You Ask, We Answer" – brought to you by Carbonfact's Science Team. Each week Dr. Laurent Vandepaer, PhD, Head of Science, together with Carbonfact's Science Associate Vincent Carrières answers one of your questions about sustainable materials, manufacturing impact, and energy transition in the apparel and footwear industry.

Before joining Carbonfact, Laurent led the integration of LCA into the sustainability and innovation efforts at On and performed LCA for other brands like Arc'teryx. Vincent joined Carbonfact after three years as a sustainability expert at Quantis, where he specialized in LCA and corporate footprinting.

30 PEFCR Questions

The EU has adopted a unified way of measuring the environmental impacts of textiles and apparel. After five years of work, the PEF Category Rules (PEFCR) for the fashion sector is now considered final, with “no further modifications” needed, has been approved by the Technical Secretariat and green-lighted by the European Commission.

As brands prepare to align with these new standards, many are left with questions about compliance, data requirements, and how to integrate PEFCR into their decarbonization strategies.

Following our recent webinar on PEFCR v3.0 for Apparel and Footwear (available on-demand) we've gathered and answered your most pressing questions about PEFCR. From handling recycled content claims to understanding the key differences between PEF and the French Eco-Score, we've got you covered.

For a general, simple-to-understand explanation of the PEF, read our deep dive into the PEF for Apparel and Footwear here.

Let's dive in!

TL;DR

• EU's PEFCR v3.1 now rewards durable, repairable products and includes microplastic shedding measurements for all textiles.
• Brands cannot use a single PEF score for consumer communications; must disclose at least four key impact indicators.
• French Eco-Score and PEFCR differ significantly; brands may need both to substantiate environmental claims across markets.

What Are the Main Updates of the PEFCR 3.0 and 3.1?

In December 2024, the EU released the first Apparel Footwear PEFCR (v3.0). Then, on 29 April 2025, (final) version 3.1 was published, turning the draft into an official rulebook and introducing key refinements.

You can find the PEFCR 3.0 here and the PEFCR 3.1 document here.

We explained all the main updates of the final PEFCR version here, if you are not yet familiar with them, then we suggest reading this article first, before diving into the Q&A in this blog.

Version 3.0 (Dec 2024): What it introduced

• Durability and Repairability Now Count Toward Your Score
• Circular Footprint Formula (CFF) Has Been Updated
• Fiber Fragment Impact Module Introduced
• Use - Phase Modelling Is Now More Realistic
• Product Lifetime (Duration of Service) Is Refined
• Packaging Modelling Has Been Improved
• New Distribution Scenarios
• Stricter Requirements for primary data
• New Guidance on Using Proxies and Secondary Data
• New Rules for Tool Verification and Software Use
• Limits on Product Comparisons

Afterward, released on 29 April 2025, Version 3.1 moved Apparel Footwear PEFCR from a draft into an operational rule set, added the first micro-plastics metric, tightened data quality and digital-tool governance, and set priorities for the next research cycle.

Version 3.1 (Apr 2025): What it refined or added

• Version 3.1 is now labeled “Final PEFCR”, valid until 31 Dec 2027. A new clause links its expiry to the release of EF database 4.0 if that comes sooner.
• Introduces a micro-plastic (fibre-fragment) impact module with inventory, factors, and examples. Every PEF study now has to measure microplastic shedding.
• Communication rules tightened – still no single score for B2C; must show at least the four most relevant environmental impact indicators. The four most commonly disclosed PEF indicators are Climate Change, Resource Use – Fossil, Water Use, and Freshwater Eutrophication, based on representative product studies. For your own product, you must disclose the top four impact categories contributing most to the single score.

What Role Will the PEFCR Play in EU Textile Regulations?

The Product Environmental Footprint Category Rules (PEFCR) for textiles and apparel will play a key role in two upcoming EU textile sustainability regulations, the Ecodesign for Sustainable Products Regulation (ESPR), Digital Product Passport (DPP), and the Green Claims Directive.

What does it mean that the PEF score is forbidden in B2C communications?

The PEFCR for apparel and footwear (version 3.1) does not allow the use of the PEF single score for business-to-consumer (B2C) communications. This means brands cannot present a single, aggregated environmental score to consumers. Instead, only the 16 impact categories (e.g. climate change, land use change, water scarcity) can be communicated with a minimum of at least the four most relevant impact indicators.

The reason for this restriction is that the European Commission is currently revising the Environmental Footprint (EF) single-score methodology to integrate missing aspects such as biodiversity and micro-fiber shedding. These additional factors are assessed through ad-hoc complementary methods, rather than being fully integrated into the single score alongside the existing 16 impact categories.

In how far is the PEF method still relevant for the Green Claims Directive as it is supposed to be used in B2B-contexts only?

Current discussions suggest that only the PEF single score might face restrictions for consumer-facing (B2C) claims, while brands could still disclose individual impact indicators (e.g. climate change, land use change, water scarcity) derived from the PEF impact assessment method (also known as the EF3.1. method). For internal use, B2B exchanges, and Green Claims/ESPR substantiation, the communication of the 16 impact categories would remain applicable.

Does the absence of the PEF single score mean it won't be part of the DPP?

If the PEF single score is not updated in time to include additional parameters (like biodiversity and micro-fiber shedding), the DPP may initially include the 16 individual impact categories and the additional environmental information instead, all based on the PEF methodology. Therefore, the product footprint might not appear as a single score at first.

Has footwear been removed from the EU Ecodesign legislation? Does this mean DPP will not be needed for footwear in this first wave?

Not to our knowledge, footwear is still in the ESPR roadmap and would be included in DPP. The first ESPR Working Plan (2025–2030), published in April 2025, confirms that textiles and apparel are among the priority product groups for the initial implementation phase. Therefore, while footwear is not explicitly removed from the ESPR, the exact timeline and requirements for its compliance, including the implementation of the DPP, will be clarified in the forthcoming delegated acts and communications.

What’s the Main Difference Between PEF and the French Eco-Score?

What's the main difference between PEF and the French Eco-Score now that durability and microplastics are included in the PEF?

The French Eco-Score (now known as Environmental Cost) is a simplified LCA-based method built for consumer-facing applications. It uses a limited set of emission factors and introduces novel parameters such as emotional durability or export of textile waste outside the EU which are pushing the discussion forward at the European level (the explicit goal of the French government).

By contrast, the PEFCR for Apparel Footwear is significantly more complex. The PEFCR is backed by a large LCA database (the EF 3.1 database) and a fully standardized impact method (the EF.3.1 method). Many of the same modeling principles used in the PEFCR also underpin parts of the French framework.

The table below summarizes some key differences between the two methods. It is not exhaustive and will likely be revisited, feel free to comment or suggest additions if you notice other relevant divergences!

How does the PEFCR work with French Eco Scores? Are both scores required or will they be required?

The French “Environmental Cost” (formerly called Éco-score) and the Apparel & Footwear PEFCR are both based on Life Cycle Assessment (LCA) methodology and share several conceptual elements. While the PEFCR served as inspiration for the French scheme, the two approaches diverge significantly on key methodological points such as scoring, durability treatment, and end-of-life modeling.

As of today, both frameworks are voluntary — neither is legally mandatory for textile brands in the EU or France. However, their legal status is evolving:

• The PEFCR is formally endorsed as the methodological reference in the EU Green Claims Directive, which is under final negotiation. If adopted, it would restrict B2C environmental claims to those based on approved Product Environmental Footprint rules, such as the PEFCR for textiles.
• The PEFCR is also likely to play a central role in the upcoming delegated acts under the EU’s Ecodesign for Sustainable Products Regulation (ESPR). In the ESPR Working Plan published in April 2025, the European Commission identified textiles as the top priority product group (source). This signals that a delegated act for textiles is imminent and it may mandate PEFCR-based footprinting (i.e. the communication of the 16 impact indicators is not restricted only the single score)

In France, the only obligation is that if a brand communicates an environmental single score, it must also disclose the French Eco-Score, and the two results must not contradict each other. In May, the French government received green light from the European Commission on the decrees formalising the French Eco-Score and is expected to launch in the summer 2025.

One year after the official launch, third parties (such as retailers or apps) will be allowed to calculate the Eco-score using publicly available data.

Though not a legal requirement, this setup creates a strong incentive for brands to calculate their own scores, because:

• Third parties will be required to use penalizing default values when optional parameters are missing
• Scores calculated by brands themselves will automatically replace third-party scores, with a maximum delay of one month

This approach is designed to encourage brands to take the lead in calculating their own environmental scores, rather than leaving it to third parties who may be working with less accurate data. Read all about the French Eco-Score for textiles here.

Why was the French Eco-Score validated by the European Commission if the PEF single score for end-consumers is forbidden?

The French Eco-Score was validated because it integrates some environmental parameters that are missing from the PEF single score, such as micro-plastics currently treated as an ad-hoc separate environmental information (i.e., not integrated in the PEF single score). The European Commission is concerned that having two diverging single scores from public authorities could create confusion. In France, if you publish a single score, you are required to include the French Eco-Score.

How do different frameworks like Ecoscore, PEF, and corporate carbon reporting result in varying impact figures?

Different frameworks impose the use of different datasets, which can lead to differences in calculated impacts. Here’s how it breaks down:

1. Ecoscore: Based on the Ecobalyse methodology, Ecoscore dictates the selection of emission factors and primarily uses datasets from sources like Ecoinvent 3.9 and French databases, such as Base Impact and Base Empreinte. These choices are regulated, and we participate in working groups to help build and improve the emission factors used across the industry.
   
   
2. PEF: PEF framework relies on a standardized database called EF 3.1, which provides consistent data for measuring environmental impact. To ensure fairness and comparability, PEF also includes a set of default datasets that brands must use unless they have primary data. Brands can create custom (bespoke) emission factors if they have more accurate or product-specific data. However, these custom factors must still follow strict PEF rules to be accepted—this ensures the results remain scientifically sound and compatible with other PEF studies.
   
   
3. Corporate-level Reporting: For corporate-level reporting (e.g. under the GHG Protocol or Organization Environmental Footprint framework), you’re not required to use the same data as in the PEF or the Ecoscore. Databases like DEFRA or spend-based approaches are allowed. However, we recommend PEF for consistency, especially if you're also reporting product-level emissions or preparing for EU regulations.

Although the Ecobalyse methodology is inspired by PEF, it differs in several areas (e.g., durability), where the French initiative identified gaps in PEF. Likewise, system boundaries and methods vary at the corporate level, contributing to further differences.

Despite these variations, many of the core parameters we collect from brands — such as production composition and weight — are consistent across frameworks and leveraged accordingly for Ecoscore, PEF, and corporate reporting.

The Carbonfact platform allows users to toggle between frameworks and observe how different methodologies and datasets affect the results. We aim to identify the greatest overlap between frameworks and achieve maximum harmonization to reduce inconsistencies, though some differences are inevitable due to the distinct data and methodologies in use.

PEFCR and Use Phase

PEFCR v3.1 has more accurate assumptions about how people care for different garments.

Do we already know how the use phase is improved? When will we have access to the new values?

The improvements to the use phase in PEFCR 3.1 focus on making washing, drying, ironing, and repair-related impacts more realistic and product-specific.

Most of the technical details are described in Section 6.4 of the PEFCR (Use Stage Modelling), which includes:

• Updated default values for consumer behavior (wash frequency, temperature, drying methods) by product sub-category.
• EU electricity mix linked to sales geography.
• Explicit modelling of repair events for products with high repairability.
• Fibre-fragment release inventories for microplastic emissions.

These refinements ensure that durable products are not penalized for having longer lifetimes, as all use-phase impacts are divided by the Specific Duration of Service.

Where can the default use value for shoes be found?

The default number of uses assigned to footwear by the PEFCR v3.1 can be found in Table 6 – “Default product duration of service per product sub-category” (Section 3.3.2.2).

The table lists the following default uses over a product's lifetime:

• Open-toed shoes: 50 uses
• Closed-toed shoes: 100 uses
• Boots: 100 uses

These values serve as the starting point for the Duration of Service (DoS) calculation and may be adjusted using the Intrinsic Durability Multiplier (IDM) and/or the Repairability Multiplier (RM).

Durability and Repairability 

PEFCR now rewards products that last longer and can be repaired. If you prove your product is durable or repairable, your environmental score improves. If you don’t provide evidence about durability, a default penalty applies (your product will be scored with a shortened lifetime). Product lifetime now depends more on product type, material, and performance.

Are durability and repairability multipliers applicable to leather footwear?

Leather footwear is not exempt from durability testing under the PEFCR v3.0. The exemption in Section 3.3.3.2 applies only to leather apparel and accessories, not footwear. Leather shoes must follow the durability process described in Annex V, using the footwear segmentation (Part II) and test tables (e.g. Table 46 for closed-toed shoes).

The Intrinsic Durability Product Score (IDPS) is calculated from physical tests (flexing, abrasion, bond strength, etc.) and converted to the Intrinsic Durability Multiplier (IDM) using the formula in Annex V, Equation 1. This IDM is then applied to the default Duration of Service (100 uses for closed shoes, Table 6).

For "durability repairability": What does "small series products" mean?

"Small series products" are those produced in limited quantities:

• Apparel: Fewer than 1,000 units globally per product reference (model + material) and no more than 500 distinct product references per year within the same apparel sub-category for the brand.
• Footwear: Fewer than 500 units globally per product reference (model + material) for the brand.

This threshold accommodates SMEs and creative fashion labels, allowing for lighter and cheaper durability testing protocols due to the lack of economies of scale.

Where can the key metrics for IDM (Intrinsic Durability Multiplier) and RM (Repairability Multiplier) be found?

You can look for § 3.3.3 Intrinsic durability and § 3.3.4 Repair/refurbish in the PEFCR v3.1.

How has the Circular Footprint Formula (CFF) been updated to include better modelling of recycled materials?

The Circular Footprint Formula (CFF) has been updated to improve modelling of end-of-life scenarios and recycled content. Key updates include revised parameters and equation layouts, increased focus on material quality (Qsin, Qsout, Qp), and allocation parameters (A, B). Additionally, the energy recovery factor (B) is now explicitly set to zero for all PEF studies, simplifying the calculations.

Microfiber Shedding PEFCR

PEFCR now includes the impact of fiber fragments (e.g. microplastics) released during care (washing, drying).

Could you clarify once more explicitly on microfibre shedding: does the PEFCR only look at products made from synthetic fibres? Are natural fibres out of scope on microplastic fibre shedding?

Textile garments and textile-labelled footwear, regardless of fibre type, must report fibre-fragment impacts. Non-laundered items such as leather or fur pieces are out of scope because no washing-stage shedding is modelled.

For products made from natural fibres (e.g., cotton-only, wool-only, or blended products), the PEF study still requires a fibre-fragment inventory. This inventory should use the relevant cotton/wool proxies from the Microfibre Consortium dataset - or preferably, primary test data - just as it would for synthetic fibres.

How reliable are the current PEFCR factors for microfibre shedding, especially when comparing synthetic and natural fibres?

The current default factors in the PEFCR use peer-reviewed datasets where available, but they still simplify important variables such as filament vs. staple construction, fabric density, and wash conditions. As a result, the model can over- or under-estimate shedding for specific products (e.g., a high-denier continuous-filament polyester jersey may shed less than a low-twist cotton staple fabric).

Because of that uncertainty, the PEFCR explicitly allows (and encourages) brands to replace the generic factors with primary test data obtained under ISO/IEC-compliant laundering protocols. Submitting robust primary results is the surest way to reflect the real shedding behaviour of a given material, and the Commission has already signalled that the micro-fibre indicator will be refined in future EF database updates as more measured data become available.

In short: the indicator is still a work-in-progress, but we need a starting point; using primary lab data is the best path to accuracy for critical products like sports tops.

Are microfibres included as an indicator in the PEF single score?

Microfibres are not aggregated into the PEF single score but are reported separately as additional environmental information.

How will a novel material be considered for the fiber fragment impacts?

The fibre fragment impact will be assessed during the product's use phase, primarily through washing. The impact depends on the material's composition. Each material will be assigned a specific fiber loss rate (based on The Microfibre Consortium’s latest annual report) and an impact factor that translates this loss into an environmental impact (based on the MariLCA research project).

Since novel materials do not have specific values from these sources, a "proxy" value will be selected. This proxy will be based on the properties of a conventional material that closely matches the novel material (e.g., staple fiber vs. filament, natural vs. synthetic).

Materials PEFCR

Can leather and synthetic leather be compared in terms of environmental footprint?

Due to the exemptions related to some products (see also section 3.8), the following restrictions regarding comparisons and comparative assertions are set:

• Genuine leather and/or fur apparel products shall not be compared to the footprint of other apparel products.
• The footprint of menstrual underwear shall not be compared to the footprint of other underwear.
• The footprint of small series for which no durability testing has been conducted shall not be compared to the footprint of other apparel and footwear products.

Does "fur vs other materials" mean that animal-free fur alternatives cannot be compared against animal-derived fur?

Scientific evidence was lacking at the time of PEFCR development to define specific durations of service and durability tests for apparel products made up of materials different from textiles (e.g., leather, fur). For these reasons, genuine fur products cannot be compared with other apparel products, including animal-free alternatives.

Do you think future versions of PEF will have a more balanced view on natural fibers? Currently wool and cotton (and bast fibers) do not measure as well as synthetics based on the bias in measurements.

The latest PEF update already moves in the right direction: by introducing Intrinsic-Durability and Repairability multipliers, products that last longer — often those made from wool, bast fibres or high-quality cotton — see their impact per use reduced, which narrows the gap with synthetics.

Future changes largely depend on the quality of LCI data and its integration into the EF4.0 database:

• If the natural-fibre sector can provide robust, up-to-date LCI datasets that capture good farming practices, soil-carbon effects, renewable energy use, etc., these datasets can be integrated into the official EF library, leading to a lower impact.
• Without primary data, the model relies on generic — or sometimes outdated — agricultural averages, which typically score higher than modern synthetic datasets that have benefited from years of industry-funded refinement.

The best way for cotton, wool, and bast-fibre stakeholders to achieve a more balanced outcome is to develop and submit high-quality, EF-compliant datasets to the Commission’s call for data ahead of the EF 4.0 update.

How can brands model novel materials not covered in the PEFCR, like industrial fermented protein fibers?

In this case, we generally conduct an LCA project with the material producer and, if applicable, a partnering brand. During this project, we would ask for a list of pre-determined primary production data (energy and water used, chemical and material inputs, waste generated...) and transform this data into an emission factor specific to your material. This emission factor would then be included in our platform database and made available to brands using the Carbonfact platform, with different restrictive access options that you can choose. 

We have already added 40+ innovative or supplier-specific materials to our platform. Read all about it here.

Will a claim of partially recycled materials require PEF to substantiate?

If you simply state the percentage of recycled content (e.g., “contains 30% recycled polyester”), EU rules require traceable chain-of-custody evidence, not a PEF study. However, if you claim that this recycled content reduces the product’s environmental impact (e.g., “30% recycled polyester makes this T-shirt greener / cuts CO₂”), the draft Green Claims Regulation requires you to substantiate the claim with an LCA covering all relevant impacts. The PEF method is the default way to do this. Therefore, recycled-content claims alone don’t mandate PEF, but any impact-reduction claim related to that content does.

Other

How are carbon credits and compensation claims handled in PEFCR?

In the PEF approach, carbon credits and compensation claims are not included in the product footprint. The methodology focuses solely on emissions directly associated with the product's life cycle, without accounting for any offsetting measures.

Carbonfact PEFCR / Next steps for brands

How can Carbonfact help?

We’re currently rolling out new features to align with the final PEFCR v3.1, which was released in May 2025.

Carbonfact is the environmental data platform built specifically for the apparel and footwear industry. Measuring the environmental footprint of a product is complex — data is often scattered across suppliers, production partners, and internal teams. As regulations tighten, doing this manually becomes not only inefficient but also unsustainable.

Our platform solves this by automating the collection, cleaning, and analysis of environmental data. We connect directly to your IT systems, flag data gaps and anomalies, and fill in missing values using the EF 3.1-compliant datasets. This ensures your footprint calculations are both reliable and fully aligned with the latest draft of the PEFCR for Apparel and Footwear.

With Carbonfact, brands can:

• Automatically calculate product-level footprints for 16 PEF indicators
• View their PEF score and French Eco-Score
• Identify carbon hotspots across the supply chain
• Simulate PEF and Eco-Scores and build data-driven reduction plans
• Report in different frameworks and easily create Digital Product Passports

Our model covers the full product life cycle and helps brands stay ahead of upcoming regulations while reducing internal workload.

What is your % margin of error for LCA calculations?

It depends considerably on the quality of the collected data and the precision of the emission factor used. Different levels of uncertainty exist in LCA calculations and are quantified:

• Data uncertainty: Missing or imprecise product or process data. To address this, we document a specific data coverage rate and create emission factors as ranges with a specific % variation. For example, if you know your product is knitted but are unsure whether it’s flat or circular knitted, we apply an average emission factor with a calculated uncertainty.
• Emission factor uncertainty: Some generic factors might not accurately represent the actual processes performed. To address this, a data quality assessment is conducted on all datasets and documented using the Data Quality Ratio (DQR) in alignment with PEFCR methodology.
• Impact calculation model uncertainty: Some LCA indicators, especially ecotoxicity or human toxicity, are less robust compared to others like climate change. A specific margin of error is specified for each indicator. For example, the climate change indicator typically assumes a 10% error margin based on the PEF method.