The Technical Secretariat and PEFCR project
The Technical Secretariat is the guiding body that is developing the PEF Category Rules (PEFCR) for the apparel & footwear industry. It is made up of representatives of various stakeholders including brands (about 50% of the European market), fibre and textile sectors, NGOs, scientific experts, and governments to ensure different perspectives in the decision-making process.
The Technical Secretariat’s work concluded in April 2025, marking the end of its mandate. While the Technical Secretariat may still make small changes to the PEFCR in the coming years, such as updates to references, a new Technical Secretariat will have to be created once the European Commission requests an official update of the methodology.
The apparel and footwear PEFCR can reduce the cost of individual PEF studies by offering tailored guidance for completing PEF studies for apparel and footwear products. The rules are publicly available here and on the Commission’s website, preventing users of the PEF method from needing to create assumptions from scratch for each study. Following a harmonised calculation framework will also make it easier to build on studies of other products in the company’s portfolio and build tools to automate LCA studies based on the PEFCR, which can help streamline the completion of PEF studies considerably.
The PEFCR methodology provides a standardised framework for assessing products’ environmental impacts. It is not a law and does not impose anything on companies. However, the methodology does facilitate the assessment of each product for companies.
Third-party verification is unnecessary when the PEF study results are used for internal purposes and assessments. However, following the European Commission’s Recommendation on Environmental Footprint methods, third-party verification is required for any external communication to consumers, suppliers, or governments.
The concept of “Duration of Service” from the Higg Product Module (PM) methodology is used in the PEFCR to define product lifetime. The PEFCR also integrates the assessment of products’ intrinsic or physical durability, which is measured through standardised testing protocols and their repairability potential. These voluntary assessments are integrated into PEF studies by adjusting the “Duration of Service” depending on the product’s and company’s performance under study.
Required Data
The PEFCR mandates using company-specific data points (i.e., product- and supply-chain-specific) that must be collected for each life cycle stage for the most relevant aspects and processes.
For all other data points, “secondary data” or “mandatory if available data” can be used. Secondary datapoints are generic and can be found in the PEFCR. Except for washing and care scenarios for LCS4, all secondary data can be replaced with primary data if desired.
PEFCR users are not expected to create datasets from scratch; the EF 3.1 database provides many relevant datasets. Users of the PEFCR will have to select the most pertinent dataset based on the primary data collected (what is used for producing this garment) for LCS1 and LCS2, and use primary data collected for energy and transport if desired. Companies can also create new EF-compliant datasets entirely based on primary data.
For a complete overview of the mandatory primary data, mandatory secondary data, and, if available, mandatory primary data, please refer to the dedicated section on this website.
Providing primary information to assess the intrinsic product quality or its repairability potential is highly recommended, but not mandatory.
Secondary data corresponds to the data that is not directly collected, measured, or estimated by the company but refers to industry averages such as statistics, other published production data, etc. The PEFCR provides default values when required, and generic datasets can be sourced from the European Commission’s Environmental Footprint (EF) 3 database.*
For example, the following default data points can be replaced by primary data for a cotton t-shirt:
Life cycle stage 1 – Raw materials – energy used to produce the cotton needed
Life cycle stage 2 – Manufacturing – energy used to knit the fabric
Life cycle stage 3 – Distribution – exact distance between the distribution centre and the place of retail where the t-shirt will be sold
Life cycle stage 4 – Use phase – Primary data cannot be used for most of the use phase, with the default data provided in the PEFCR being mandatory
Life cycle stage 5 – End of life – exact share of waste landfilled, recycled or incinerated in the countries where the t-shirt is sold
The deadstock rate and fate, assessed at each stage of the product life cycle, are part of the mandatory primary data. This enables accounting for potential loss over the entire product life, not only during manufacturing or at the end of life.
Data developers develop the EF database based on literature reviews and primary data from companies. It is verified, validated, and managed by the European Commission to ensure transparency and robustness. The current version of the database is EF3.1. It is the only fully EF-compliant database, and it will be accessible for free when used together with the PEFCR for Apparel and Footwear. The EF 3.1 will expire after 31 December 2025, and is set to be replaced by a new generation of the database, EF 4.0, in 2026 or 2027. In the interim, companies will need to purchase other EF-compliant datasets for those datasets that will not be extended to complete PEF-compliant studies based on the PEFCR.
The PEF method follows the materiality principle – focusing primary data needs on what matters most regarding environmental impacts and providing secondary data for the rest. Based on the primary data collected, the users of the PEFCR will have to select the most relevant secondary datasets from the EF database. For example, companies will be asked to pick the best cotton dataset to reflect their products’ origin and yarn size. For the rest, the default values provided in the PEFCR can be used to, for instance, model the distribution pathway for a typical t-shirt. Companies can also create new EF-compliant datasets entirely based on primary data.
Accessibility
Adopting a PEFCR facilitates the accessibility of the PEF method for SMEs in several ways that ensure they can compete on sustainability with larger companies. PEFCRs are freely available here and on the European Commission’s website and can be used to access the official EF3.1 database without additional costt. They detail assumptions and calculation rules, eliminating the need for companies to reinvent the wheel every time they run a study. The standardisation of default secondary data and calculation rules also makes it easier for companies to build on previous LCAs from their portfolio and automate LCA studies. Companies do not have to invest in developing proprietary LCA methodologies or purchasing access to needed secondary datasets.
This means that the cost of running a comprehensive LCA can be reduced from €50,000 — €100,000 to only €250 when collaborating with tool providers offering streamlined applications of PEFCRs. Depending on the complexity and scale of the PEF studies being run this cost can be further reduced to a significant degree.
Implementation
The apparel and footwear PEFCR’s validity is tied to the validity of the EF 3.1 database. This means the methodology is valid until 31 December 2025. Minor updates, such as correcting references, can be implemented by the Technical Secretariat alone. Larger updates, such as expanding the methodology’s fibre fragment assessment method, would currently trigger the standard PEFCR development procedure, including supporting studies and public consultations.
The European Commission has made efforts to outline the requirements for Business-to-Consumer environmental claims under the “Substantiating Green Claims Initiative.” This initiative was started to clarify the conditions and requirements for making environmental claims based on environmental footprinting.
According to the requirements of the PEF method, companies can communicate the results of PEF studies to consumers or business partners once they have successfully gone through the mandatory verification process. The PEFCR for apparel and footwear specifically allows companies to communicate the results of their PEF studies to other businesses or the government without any restrictions. For Business-to-Consumer communication, the PEFCR currently does not allow the communication of single score results. However, it will enable companies to communicate the impacts of the four most relevant categories identified to consumers.
What is measured via the PEF?
The Product Environmental Footprint (PEF) assesses the impact at the product level. Therefore, it does not directly consider production at the company level. To consider a company’s total production, one would perform a corporate footprint using the Organisational Environmental Footprint (OEF) method.
PEF study results provide an aggregated single score expressed in points.
Each impact category result is communicated using its unit:
- Climate change: kg CO2-eq
- Ozone depletion: kg CFC-11-eq
- Human toxicity, cancer: CTUh
- Human toxicity, non-cancer: CTUh
- Particulate matter: disease incidence
- Ionising radiation, human health: kBq U 235 -eq
- Photochemical ozone formation, human health: kg NMVOC – eq
- Acidification: mol H+ – eq
- Eutrophication, terrestrial: mol N -eq
- Eutrophication, freshwater: kg P – eq
- Eutrophication, marine: kg N -eq
- Ecotoxicity, freshwater: CTUe
- Land use: pt
- Water use: m3 world -eq
- Resource minerals and metals: kg Sb – eq
- Resource use, fossils: MJ.
Renewable materials are included in the PEF method through tailored modelling rules for biogenic carbon (i.e. carbon coming from biomass). Carbon emissions into the air resulting from renewable sources emitted through combustion, composting, landfilling at the end of life, etc., are not included in the environmental footprint calculations. These emissions are reabsorbed from the atmosphere through photosynthesis during biomass growth.
Recyclability is fully covered by the Circular Footprint Formula (CFF), created by a scientific division of the European Commission, the Joint Research Centre (JRC).
Recycled Content can also be integrated into PEF studies by selecting appropriate EF 3.1 datasets. For recycled wool, for instance, selecting recycled wool instead of virgin wool effectively reduces the environmental impacts from materials used to nearly zero.
Biodegradability is partially covered by the CFF (composting) and specific toxicity and ecotoxicity modelling rules. Other advantages of biodegradability, like lower microplastic pollution, cannot be considered within the LCA method today since precise impact assessment methodologies are still evolving.
Social aspects are not covered by the Product Environmental Footprint, which only measures products’ environmental impacts.
Microplastic pollution is partially covered in the PEFCR for apparel and footwear, reflecting some life-cycle impacts from microplastics. This is ensured through the fibre fragment assessment method, which covers both synthetic and natural materials and is currently limited to releasing fibre fragments through washing of apparel and footwear during the use phase. The assessment of impacts is limited to the marine environment.
The assessment method consists of two main steps: (1) an inventory assessment, which provides the mass of fibre fragments released, and (2) an impact assessment, which uses the results from step (1) to quantify the product’s impact on the marine environment.
While not perfect, this assessment method used the best available scientific approaches when developing the methodology to integrate an assessment of the impacts of microplastics in the PEFCR. This goes beyond what the current general framework of the EF methods requires to recognise the critical role that microplastics and fibre fragments play. The limitations of the current approach are clearly highlighted in the PEFCR.
The European Commission is set to publish a new version of its Recommendation on the Use of EF Methods in 2026. The Commission has announced its ambition to include a more standardised and complete assessment of fibre fragment releases and impacts.
While human activity associated with each material is measured consistently, natural fibres and synthetics significantly impact different areas across their life cycle:
- Synthetic fibres pose a challenge at the end of their life as they cannot biodegrade, meaning that plastic stays in the environment for a long time. As mentioned before, microplastic pollution’s impacts are still difficult to assess accurately over the entire life cycle. It is also important to note that the impacts from forming non-renewable raw materials (i.e., oil or natural gas) are not considered in the PEF method, as their formation happened millions of years ago. This approach follows the current accounting approach established by the International Panel on Climate Change (IPCC) and general scientific consensus among LCA experts. Per this consensus, the PEF method includes the extraction of fossil resources and a dedicated “fossil resource use” indicator. This second indicator reflects that fossil resources to produce synthetic materials are finite, while the raw materials used for producing natural fibres are renewable.
- While inherently more circular and biodegradable, natural fibres (i.e., cotton, flax, wool, hides and skin) have high impacts in other areas like land use and water consumption. These impact areas have been consistently linked to agricultural practices. Notably, past agricultural effects, such as deforestation beyond a cut-off of 20 years, are not considered in LCA. However, the impacts of forming renewable raw materials through farming and agriculture are counted. This follows the current accounting approach established by the International Panel on Climate Change (IPCC) and general scientific consensus among LCA experts.
Glossary
EF compliant dataset: A dataset developed in compliance with the EF requirements provided here.
Life cycle approach: This approach considers the spectrum of resource flows and environmental interventions associated with a product from a supply chain perspective, including all stages from raw material acquisition through processing, distribution, use, and end-of-life processes and all relevant related environmental impacts (instead of focusing on a single issue).
Life Cycle Assessment (LCA): Compilation and evaluation of a product system’s inputs, outputs and potential environmental impacts throughout its life cycle (ISO 14040:2006). More information can be found in this section of this website.
PEF Methodology: EU-recommended Life Cycle Assessment (LCA) based methods to quantify the environmental impacts of products (goods or services). The overarching purpose of PEF information is to enable the reduction of the environmental impacts of goods and/or services, taking into account supply chain activities (from the extraction of raw materials, through production and use to final waste management). This purpose is achieved through the provision of detailed requirements for modelling the environmental impacts of the flows of material/energy and the emissions and waste streams associated with a product or an organisation throughout the life cycle. Reference
Primary data: Directly measured or collected data from one or multiple facilities (site-specific data) that are representative of the activities of the company. To determine the level of representativeness, a sampling procedure may be applied.
Product Environmental Footprint Category Rules (PEFCR): PEFCRs are product category-specific, lifecycle-based rules that complement general methodological guidance for PEF studies by providing further specification at a specific product category level. PEFCRs help to shift the focus of the PEF study towards those aspects and parameters that matter the most, and hence contribute to increased relevance, reproducibility and consistency of the results by reducing costs versus a study based on the comprehensive requirements of the PEF method. Only the PEFCRs listed on the European Commission website are recognised as in line with this method.
Secondary data: Data not from a specific process within the supply chain of the company performing a PEF study. This refers to data that is not directly collected, measured, or estimated by the company, but sourced from a third-party LCI database or other sources. Secondary data includes industry average data (e.g., from published production data, government statistics, and industry associations), literature studies, engineering studies and patents, and may also be based on financial data, contain proxy data, or other generic data. Primary data that goes through a horizontal aggregation step is considered secondary data.
Technical Advisory Board (TAB): Group composed of a maximum of 100 permanent members. The task of the TAB is to assist the Commission in implementing existing Union legislation, programmes, and policies. It provides advice and expertise to the Commission. The issues to be discussed might include, but are not limited to, analysis of the content of newly developed PEFCRs/OEFSRs, consistency of approaches among different PEFCRs/OEFSRs, and new methodological developments seen as necessary within the EF context. Reference
Getting Terms Right
