Status: ✅ Approved EU 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. After five years of work, the PEFCR for the fashion sector is now considered final, with “no further modifications” needed, and has been approved by the Technical Secretariat and green-lighted by the European Commission.
You can find the latest version (v3.1) of the full PEFCR guideline here.
The new PEFCR rules present a single, science-based method for product footprints, streamline compliance with the upcoming EU Green Claims Directive and Eco-design Rules, and set a common language amongst brands, suppliers, and auditors.
The dynamic and technical nature of these emergent frameworks is a lot to digest. That’s why we’re taking an easy-to-understand deep dive into the European PEF and how fashion and textile brands can prepare.
Jump straight to what’s new in PEFCR v3.1 for Apparel and Footwear.
What is the PEF methodology?
Life Cycle Assessment (LCA) is a broad method for evaluating a product’s environmental impact across its entire life cycle. To ensure greater consistency and comparability, the EU developed the Product Environmental Footprint (PEF) — a standardized framework that assesses environmental performance from raw material extraction and manufacturing to distribution, use, and end-of-life.
In essence, a PEF study is an LCA conducted using a harmonized set of rules and data requirements.
The PEF Guide was first introduced in 2013 and finalized in May 2025, in response to the growing need for consistent and transparent environmental claims across the European Union.
Apparel & Footwear PEFCR
Housed within the PEF method are PEF Category Rules (PEFCR), designed to provide more specific guidelines for individual product categories. Developed by a multi-stakeholder Technical Secretariat, the PEFCR has gone through public consultations, expert reviews, and validation by the European Commission.
The Technical Secretariat analyzed a complex industry to create a set of rules that are accessible to brands of all sizes while remaining precise enough for comprehensive PEF studies.
- Circularity – including recycled content and recyclability
- Durability – how long products are worn in practice
- Repairability – the ability to extend product lifespan
The Apparel and Footwear PEFCR covers all garment and footwear categories, broken 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
Some impact factors are still evolving. In PEFCR v3.1, microplastic pollution is partially addressed through a dedicated module, while biodiversity remains a future development priority.
What’s included in the PEFCR scope?
The PEFCR is a highly technical framework developed by and for LCA experts. Below are the key elements fashion brands should understand.
PEFCR includes 16 impact categories, covering far more than climate change alone.
- Climate change – total
- Ozone depletion
- Human toxicity (cancer & non-cancer)
- Particulate matter
- Ionizing radiation
- Photochemical ozone formation
- Acidification
- Eutrophication (terrestrial, freshwater, marine)
- Ecotoxicity – freshwater
- Land use
- Water use
- Resource use – fossil fuels
- Resource use – minerals and metals
Each product receives an individual PEF score derived from these impact categories.
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How can Carbonfact help?
Carbonfact is the environmental data platform built specifically for the apparel and footwear industry. We automate data collection, apply EF 3.1-compliant datasets, and help brands stay aligned with evolving EU regulations.
Lidia Lüttin
