Why fashion brands should consider PEF for their LCA methodology

The apparel and footwear industry employs a wide range of methodologies, certifications, and product labels. They are needed to measure the environmental footprint of products and eventually tackle those hotspots, but there is a problem: outcomes are hard to compare.

That is why there is a growing need for a universal, aligned methodology. One potential EU-wide solution is called Product Environmental Footprint (PEF). PEF omes down to a standardized LCA, aimed at evaluating the environmental impact of products consistently throughout the European Union.

The methodology uses the approach of so-called Product Environmental Footprint Category Rules (PEFCR) to adapt the framework to specific product groups.

The single set of rules developed for Apparel and Footwear includes 13 product types, from ‘sweaters and mid-layers’ to ‘open-toed shoes’.

The long road to PEF

Already back in 2010, the idea of a standardized impact measurement within the EU was established. The development of the PEF started in 2013 with the first cycle ending in 2018.

The official introduction was in the 2020 Circular Economy Action Plan (CEAP), one of the main building blocks of the European Green Deal, and the Sustainable Products Initiative (CPI), which aims to make products placed on EU markets more sustainable.

It’s likely that PEF will be formally integrated into the CEAP and SPI, the Green Claims Initiative, the revised Ecodesign Directive, and other, future legislations. But we’re not there yet. Until PEF can be officially implemented, some more steps are required.

Following the first public consultation published in 2021, brands are currently experimenting with this up-to-date version. Their reviews will be articulated in a final consultation that is expected to be published in 2023.

By 2024, the PEF will be submitted to the European Commission for final adaptation, so it’s time to have a closer look at the scope of PEF.

Why PEF is complementary to LCA

In short, PEF is a methodology to standardize the way the environmental footprint of products is measured. By following a product-specific set of science-backed rules, apparel and footwear companies can guarantee consistent measuring of their products’ ecological footprints.

In this way, PEF provides a strong foundation for the ambitious objectives set by the European Union on the way to a circular economy, such as making competitive sustainable products the norm and empowering consumers and public buyers in their decision-making.

“The PEF is like a common LCA language”, explains Michela Sciarrone, Sustainability Analyst and PEF-Expert at Sustainable Brand Platform. “LCA’s are based on numerous assumptions that can differ greatly, based on who is performing the LCA and the available information. PEF gives you all these assumptions in advance, so you only have to make the calculations for your product. This standardized approach makes same or similar products LCA-consistent.”

The wide variety of impact measurement tools that are currently available can't promise that. At this moment, 230 distinct environmental labels circulate within Europe, which undermines conscious decision-making.

It also makes it harder for companies to identify impact hotspots and see opportunities to make their products more sustainable. After all, eco-design thrives on focused innovation efforts and clearly identified areas of improvement.

PEF on the other hand is very comprehensive, employing 16 environmental indicators, such as water use and freshwater ecotoxicity. They help supply chain and sustainability managers identify the impact hotspots of, for example, a t-shirt or sneakers.

So they can use these learnings for improved eco-design. Moreover, working with pre-defined and verified industry rules on impact measurement saves time and facilitates comparison.

Sciarrone gives the example of a t-shirt to illustrate the issue of general LCA’s. “Two people could do two correct LCAs about the same shirt and those can have really different results.” ‍

That is because LCAs come with different system boundaries. A generic ISO 14040/44 compliant LCA leaves room for interpretation on aspects like impact allocation, system boundaries, LCIA methodology, bringing to results that can differ greatly even if applied to the exact same product.

For example, you can decide to include production only (cradle-to-gate) and leave out the use phase and end of life. If you do that, you can’t compare the results with a shirt that is fully accounted for cradle-to-cradle or cradle-to-grave.

‍“The main goal the European Union has with PEF is to design a comparable methodology and thereby, in the long run, decrease the impact along all phases.” - so Sciarrone.

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Category rules for consistent measures

Since 2019, the category rules for apparel and footwear have been developed by a Technical Secretariat, which is coordinated by the Sustainable Apparel Coalition and composed of scientists and half of Europe’s leading apparel companies (from fibers and textiles to ready-made garments).

The European Commission and NGOs keep an eye from the sidelines. For the sake of consistency and comparability, this group of experts made sure to limit the flexibility in assumptions.

For example, brands might claim their t-shirt can be worn a thousand times before it wears out, but PEF gives you a standard number of ‘wears’ based on average consumer use.

This should be multiplied by the total impact calculated by the software to get the total footprint over the use phase (washing, drying, ironing). Similarly, distribution comes with default values based on mapped distances within Europe.

Moreover, a standardized approach to the number of wears weighted with values like the quality indicator can be used to bring relevant nuances in the impact per use value. This could be the best indicator for a consumer to evaluate the sustainability of a product.

However, it is always best to use specific data if readily available. From electricity use to chemical inputs, all data must be inserted into the LCA software. The output is a summary of environmental impacts shown as a dashboard of 16 PEF impact categories, covering problems in five areas such as climate change and human health.

4 steps to PEF

Step 1

As with every LCA, you as supply chain or sustainability manager in charge of the environmental footprint measuring process would have to start with defining your company’s goal and scope.

Already at this very early stage, PEF comes in with science-based rules, since the options are limited to the predefined PEF categories for apparel.

Step 2

The second step encompasses data collection and an overview of robust data quality. For example, data must be timely and must represent the right geographic zone.

To limit the use of generic public databases for company-relevant processes, you must also provide a minimum list of processes to be covered by company-specific data.

Furthermore, this stage involves inventory modeling, which means defining all input and output material and energy flows. For the latter, PEF has specific rules to account for recycled materials.

Step 3

Recycling plays a vital role in the growth of a global circular economy since it allows us to preserve valuable resources and minimize the extraction of new raw materials.

That is why LCA methods need to be able to model waste and recycled materials and to allocate adequate environmental burdens and credits to users and producers that use them.

This is where the PEF’s well-constructed Circular Footprint Formula (CFF) comes in handy. It sums up all burdens and credits from a product’s recycled and recyclable material, the waste leaving the system and the energy used and recovered in this process to determine its circularity value.

The CFF makes a great example of the effectiveness of PEF in creating a fair, transparent sustainability language for fashion brands.

Step 4

This elaborate second step is followed by the actual impact assessment, through which the different impact categories are interpreted. It involves technical phases such as classification, normalization, and weighting.

As a fourth step, interpretations are reported and verified. This part also includes an improvement assessment.

Example: The PEF of a pair of heels

Let’s take heels as an example. “Heels are usually not washed nor recycled, but according to the PEF, you would still have to work cradle-to-cradle. After all, they do have an end of life at a landfill or incinerator”, Sciarrone explains.

Then, you can either decide to calculate the impact over its entire life or for a single use. So, if the pair is worn a hundred times, you would have to divide its final footprint by a hundred.

Assuming a component of this specific pair is made of plastic, you start with the extraction of resources and then consider all the water, chemicals, and energy used for plastic production and shoe manufacturing.

For the distribution phase – from supplier to manufacturer to retail – you add all distances and transportation types of the different material flows including the packaging. For direct sales through online stores, you add the emission for the server.

In the case of warehousing, you must account for things like emissions from the storage. Sciarrone: “If you leave the product there for seven weeks, the warehouse is going to be using electricity for the lights, heat, or cooling. Say that you have a thousand pairs of heels inside the warehouse, then you would take all emissions for that period and divide it by seven (weeks) and by a thousand (pairs).”

‍Losses are also part of the production outputs, Sciarrone explains. “If you’re producing a plastic product using molds, there can be plastic leftovers. If it cannot be remelted, it is thrown away and that has to be accounted for in the total impact.

So say you’d a product consists of 30 grams of plastic, but you need 50 grams to make it, you have to account for the whole impact - not just CO2-equivalents - of those 20 grams of waste”.

Another challenge in general LCA starts once products have found their owners, “because after you’ve sold it to the consumer, you don't know what happens to it”, says Sciarrone. “There are different scenarios including resale, incineration, and landfill with very different implications. For example, incineration has a positive impact on energy recovery, but landfill allows for methane recovery. Since you can't know where they end up, PEF gives you some average probability percentages.”

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Example: The PEF of a t-shirt

Whereas the impact heels are generally not washed, dried, and ironed, this use stage makes up a significant part of the impact of a t-shirt. Here too, PEF offers the tools to get reliable estimates.

Sciarrone: “You apply different rates for cleaning depending on the type of product and material. Machines will have a bigger impact since they consume more water and electricity for a single wash, so if machine washing is used 20 percent of the time and the rest is hand washed, your impact value per use will have a relatively lower rate. PEF gives you some default values in case you don't know, but you should change them according to the care instructions given by the brand.”

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How PEF takes care of data quality

In the process of calculating your impact, the source of these data matters too.

“PEF comes with an official methodology to calculate how good the data is,” says Sciarrone, “because if you produce in Italy and use data from China, you need to ask yourself: how similar is the technology? How old is the data? After assigning a score depending on the answers to those questions, you then assign an average score to the quality of the data that you're using over the entire study.”

Compared to a standard LCA, the PEF methodology imposes much stricter regulations. But it is exactly this comprehensive and prescribed analytical approach that ensures the consistency the industry needs to compare products in a fair manner. ­­

That is why PEF is a much-needed development within the EU’s plans for a circular fashion industry forward. By implementing a standardized science-based approach, brands can take responsibility, improve their processes, and provide clarity for consumers and industry members.

Future perspective and criticism

PEF is not yet put into action. The next phase is an active pilot scheduled for completion by the end of 2024. Rules are still being developed, and both positive and negative feedback are part of that process.

Criticism includes missing impacts, such as the shedding of microfibers that distort the impact values of (partially) synthetic products. Industry experts are asking for better guidelines for data quality rating, using an approach that would favor primary over secondary data.

There is also a need for more transparency around the Environmental Footprint (EF) database. Ideally, the original objective of PEF continues to serve as the guiding principle: to establish a uniform methodology for creating product footprints within the EU.

That should make it easier for sustainability and supply chain managers to compare the sustainable performance of their products, scout best practices in the industry, and set ambitious ethical standards themselves.

Ready to start? Our LCA tool for fashion companies allows you to calculate your product impacts based on PEF methodology. Get in touch with us here.