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 Product Environmental Footprint Category Rules (PEFCR) for the fashion sector are now considered final, with “no further modifications” needed. A formal vote to submit the rules for approval by the European Commission is expected in late April 2025.
You can find the latest version (v3.0) of the full PEFCR guideline here.
The new PEFCR rules make it clearer how to measure the environmental impact of fashion products. They now take into account how long a product lasts, how easily it can be repaired, and even how it’s washed, packaged, and shipped. Brands will need to use more accurate data and follow stricter rules if they want to make environmental claims or comply with upcoming EU regulations.
[Read here: What’s New in PEFCR v3.0 for Apparel and Footwear]
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.
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 updated in December 2021, in response to the growing need for consistent and transparent environmental claims across the European Union.
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 two public consultations, several expert reviews, and validation by the European Commission. It is set to become the EU’s reference methodology for calculating and communicating the environmental footprint of textile and clothing products.
The Technical Secretariat had 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 standardized methodology of this scale had ever been developed for assessing the environmental impact of apparel and footwear. To create the PEFCR, the Technical Secretariat considered several key factors that reflect how products are actually made, used, and disposed of:
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:
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 transparent about the environmental impact factors that are still in development. With version 3.0, microplastic pollution (via fibre fragment release) is now partially addressed through a dedicated impact module, though it remains an evolving area. Similarly, biodiversity is flagged as a future development priority, and the group continues to await further guidance on how to factor in second-hand use and reuse scenarios when calculating product lifespan.
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. In PEFCR 3.0, all results must be calculated using the EF 3.1 reference package and the latest EF-compliant datasets.
While the PEFCR is now finalized, it is still awaiting formal adoption by the European Commission. It is expected to encompass the following impact categories:
Resource Use – minerals and metals: assesses the use and depletion of non-renewable mineral and metal resources.
It’s important to note that in PEFCR v3.0, if the impact category ‘Climate change – total’ is reported, its three sub-categories (‘Climate change – fossil’, ‘Climate change – biogenic’, and ‘Climate change – land use and land use change’) must also be disclosed separately when each contributes more than 5% to the total climate change score.
Additionally, while biodiversity is still not included as a separate impact category, PEFCR v3.0 highlights it as a priority for future development. Fibre fragment pollution is now partially addressed through a dedicated impact module, although this is still considered an evolving area.
Each of your products will have an individual PEF score, along with high-level information about how it was calculated. Each of the impact categories mentioned above contributes a percentage to this score. For example, climate change still carries the highest weighting, but in PEFCR v3.0, the weighting values have been updated to reflect the latest scientific insights and stakeholder input. These weightings determine how much each impact category influences the final score, helping to prioritize actions across the product’s lifecycle.
PEF score in Carbonfact - Sustainability platform
The final PEF score is calculated by applying these weightings to the results of each impact category and summing them into a single figure.
Note: Certain product types such as leather, fur, menstrual underwear, and small-series products without durability testing are excluded from comparative claims under PEFCR v3.0.
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.
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.
Representative Products: Embodying the “market average” in terms of environmental performance, these products will utilize either industry-average data or a weighted mix of primary and secondary data. The representative product’s average performance and impacts will be calculated, serving as a benchmark for verifying whether an individual product is eligible for comparative claims.
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:
Verification: There are baseline verification requirements consistent across all PEFCRs, encompassing both the scope of verification tasks and the qualifications required of the verifier. In PEFCR v3.0, additional rules now apply to software tools used for footprint calculations—including pre-verification, version control, and annual reviews for high-volume tools.
Individual PEFCRs may also have further verification requirements for specific modules like durability or repairability scoring.
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.
Under PEFCR 3.0, brands must provide primary data for at least 95% of the product’s Bill of Materials (BOM) by weight. This includes data such as material weight, composition, supplier processes, and transport modes. Some high-impact indicators—like the percentage of products shipped by air or the share of unsold stock—are now mandatory.
When primary data isn’t available, brands are allowed to use secondary datasets—but only under specific conditions. The Data Needs Matrix (DNM) introduced in v3.0 provides clear guidance based on how much control or visibility a brand has over its supply chain. It outlines three scenarios:
Each scenario comes with recommended fallback approaches, helping brands choose the most accurate proxy datasets while staying compliant.
It’s worth noting that all secondary data used must come from EF-compliant datasets (version 3.1 or newer), ensuring consistency across the industry.
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 an updated secondary dataset — known as EF 3.1 — which contains detailed secondary data for apparel and footwear that companies must use. Only EF-compliant datasets are allowed in PEFCR v3.0, ensuring that all studies are based on consistent assumptions and methodologies. These datasets are available via platforms such as Ecoinvent, and may also be embedded into verified PEF calculation tools.
The PEF method follows the “materiality principle” — which means focusing effort on what matters most (i.e. the processes with the biggest impact) and applying secondary data for the rest. In PEFCR v3.0, brands must select the most appropriate dataset from the EF database based on available primary data. For example, brands should choose the best-fitting cotton dataset by matching origin, fibre type, and yarn size. For background processes with low impact or low data visibility—such as the distribution pathway of a typical dress—the PEFCR provides default data that can be used.
Read how Carbonfact applies this principle with Supply Chain Blueprints.
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.
Microplastics, which were previously excluded, are now partially addressed through a new fibre fragment impact module introduced in PEFCR 3.0. This module estimates microfibre release during garment care (e.g. washing), particularly from synthetic fabrics, and links it to marine ecosystem damage. However, this approach is still based on emerging science and does not yet include broader health impacts. As Baptiste Carrière-Pradal recently noted, this represents an important first step—but further development is needed to reflect the full extent of the issue, especially once consensus on a “planetary boundary” for microplastics is reached.
Similarly, adding biodiversity as a formal impact category remains a challenge. It functions as an endpoint indicator—capturing complex, long-term effects—while existing PEF categories are mid-point indicators based on more measurable, cause-based factors. The lack of a standardised, science-based methodology continues to delay its inclusion, although it is highlighted in PEFCR v3.0 as a future area of development.
Chemical exposure is another significant blind spot for the fashion industry, given the continued use of toxic substances like PFAS. While the UseTox methodology is currently used to model toxicity in LCA, it only covers emissions to air, water, and soil—not direct exposure to humans via skin contact or fibre inhalation, which are critical concerns in apparel.
The PEFCR also does not yet account for social impacts or animal welfare. Social issues such as child labor, modern slavery, and livelihood risks for farmers are currently better addressed through legislation and due diligence frameworks (e.g. EU’s Corporate Sustainability Due Diligence Directive). These are often considered “black and white” issues, making them difficult to model through LCA tools. Meanwhile, animal welfare remains highly contested, as there is no widely accepted method for quantifying the environmental or ethical impact of using animal-derived materials.
As Baptiste Carrière-Pradal emphasized, it’s essential to understand what PEF is—and isn’t. It is a science-based tool designed to quantify environmental impact, not a value-based tool that captures ethics, culture, or political priorities. The PEFCR should not be viewed as the only decision-making tool, but rather one piece of a broader sustainability strategy that includes regulation, consumer values, and industry-specific context.
The Product Environmental Footprint Category Rules (PEFCR) for textiles and apparel will play a key role in supporting several upcoming and existing EU sustainability regulations. These regulations aim to harmonize environmental claims, product design, and transparency across the textile and fashion industry. Here’s an overview of the most relevant legislation:
⸻
Status: Finalized in 2024, entering implementation phase.
⸻
Status: Proposal adopted by EU Parliament in March 2024; pending final approval.
⸻
Status: In effect since January 2024 for large companies; phased rollout ongoing.
Carbonfact is an environmental sustainability platform, built for apparel and footwear. We know that measuring a garment’s environmental footprint is a complex task. Manually gathering and consolidating data across outsourced manufacturing, as well as your own business is not only error-prone – it’s also unsustainable as new laws increase reporting requirements.
Our platform 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 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:
[i] https://pefapparelandfootwear.eu/whats-behind-the-methodology/
[ii] https://www.carbonfact.com/hubfs/PEFCR%20Apparel%20&%20Footwear.pdf