The apparel and footwear PEFCR in more detail
What products are covered by the PEFCR?
The apparel & footwear PEFCR covers all categories of garments and footwear with 13 product sub-categories
What other essential factors are considered in the PEFCR to improve the environmental footprint of apparel and footwear?
> Circularity
They provide rules to assess circularity in two cases:
- If the product uses recycled materials.
- If the product is recycled after use, should it be turned into new garments or used for any other purpose.
> Durability
Durability is key to extending the life of apparel and footwear products and thus improving their environmental impacts. Durability refers to a product’s lifespan and how often it can be worn, given the properties of used fibres, its resistance (e.g. sole abrasion), and appearance (e.g. pilling, or colourfastness testing).
The PEFCR reflects products’ physical durability and encourages the integration of emotional durability once more solid scientific approaches have been developed.
> Repairability
Repairability helps extend a product’s lifespan by maintaining it in good condition.
The PEFCR rewards the possibility, availability, and accessibility of repair to reflect that repairability promotes reusability and eco-design practices.
> Fibre Fragments
Fibre fragments, including microplastics, are small pieces of fibre shed from various products throughout their life cycle. This also happens with apparel and footwear products.
Fibre fragment shedding impacts the environment differently depending on the materials used. The PEFCR for apparel and footwear partially covers these impacts and presents them as additional environmental information.
Companies tested the PEFCR on real products on the EU market during the supporting studies and incorporated feedback into an updated version before submitting it for the second public consultation.
What other aspects are currently not included in the PEF methodology and why?
The Technical Secretariat and the European Commission recognise that the impacts from fibre fragments should be assessed for the entire product life cycle. To start this integration, the TS developed a limited approach in the PEFCR for apparel and footwear covering washing during the use phase and impacts on marine biota.
Additionally…
…the EF methods will continue to evolve to meet these requirements as more scientific data and evidence become available.
…the Commission shared its ambition to integrate the impacts from fibre fragments into the general framework of the EF methods.
…the Commission is developing a 17th impact category for biodiversity, which is to be included in the next version of the EF methods.
> Fibre Fragment Pollution
Methodologies to assess fibre fragment pollution, including microplastic leakage, throughout products’ life cycles, are still in development.
The PEFCR for apparel and footwear considers fibre fragment shedding through washing during the use phase. Additionally, it quantifies the impact that those fibres have on marine biota. The methodology highlights the need to expand this assessment framework and its limitations.
> Biodiversity
The PEF method includes at least eight impact categories that also affect biodiversity. These include climate change, aquatic freshwater eutrophication, aquatic marine eutrophication, terrestrial eutrophication, acidification, water use, land use, and freshwater ecotoxicity. There is currently no dedicated “biodiversity” impact category since an international consensus on a life cycle impact assessment method capturing that impact did not exist when the Commission’s last recommendation on the EF methods was developed in 2021.
The European Commission is expected to present such a method in 2026, building on several years of cooperation with an expert group who submitted a technical recommendation in 2022.
> Volumetric
As the PEFCR is product-focused, the current version of the rules does not evaluate the quantity of products brands put on the market. It does not take into account the company’s environmental footprint, which would include the number of collections produced. The Organisational Environmental Footprint (OEF) method, also developed by the European Commission, can quantify environmental impacts at the company level.
> Second-hand labelling
The PEF method calculates the impact of products for their entire lifetime until they can no longer be used. This means it does not consider the number of users but solely focuses on how long the product can be used.
For example, it is estimated that a t-shirt can be worn 45 times, which could be:
- 45 uses with the same user;
- 20 uses with a first user, and 25 with a second user after the t-shirt has been donated for reuse.
What data will companies need to provide?
Companies will be required to collect and report two types of data:
> Primary data
Company-specific data provided directly by companies or indirectly by suppliers (i.e., product-specific and supply chain-specific data)
> Secondary data
Industry averages, such as statistics or other published production data, that the company does not directly measure or estimate. When required, the PEFCR provides default values. Generic datasets can be sourced from the European Commission’s Environmental Footprint (EF) 3.1 database.
Data requirements
Primary data is required for the most relevant life cycle stages, as identified following the PEF method. Secondary data can be used for less relevant processes and life cycle stages.
To reflect that different users of the PEFCR for apparel and footwear will have various levels of supply chain visibility and available resources, it introduces three data requirement categories:
- Mandatory primary data,
- Mandatory primary data, if available,
- Mandatory secondary data.
Category 3. is only relevant for Life Cycle Stage 4, the use phase. For category 2., the PEFCR provides secondary default values that can be used if primary data is unavailable.
This section outlines the data needed for the five life cycle stages following the three data requirement categories defined in this introduction.
Primary data is also used to select the most relevant secondary datasets for each process used to produce the studied product. The secondary datasets are listed in Annexe VII of the PEFCR for apparel and footwear.
Except for Life Cycle Stage 4, companies are encouraged to build primary datasets with company-specific information to replace the need for secondary datasets.
> Life Cycle Stage 1: Raw Materials (except packaging)
- Mandatory Primary Data
- Bill of Materials (BOM) by weight, covering at least 95% of the product, including 100% of main fabrics, lining, padding, electronic parts, and metals; must include material losses
- if BOM is unavailable, product weight and reference size
- origin of materials used in the BOM; exception: commodities
- information related to yarn type, textile formation and finishing techniques
- raw material mass transported.
- Mandatory Primary Data, If Available
- raw material transport distances, modes, provenance (share of total transport), and lorry utilisation rate.
> Life Cycle Stage 2: Manufacturing
- Mandatory Primary Data
- if the BOM is unavailable, the product assembly loss rate
- intermediate and finished product mass transported.
- Mandatory Primary Data, If Available
- manufacturing technologies
- weighted Average processing loss rates at company- or product-category level
- energy mix to select the most relevant manufacturing datasets (SMEs are exempt)
- semi-finished and intermediate product transport distances, transport modes, share of product mass transported, lorry utilisation rate.
> Life Cycle Stage 3: Distribution
- Mandatory Primary Data
- final product weight
- air cargo distance at the company level
- air cargo share of product mass transported for each origin at the company level.
- Mandatory Primary Data, If Available
- product transportation distances, modes, share of product mass transported for each origin, and lorry utilisation rate
> Life cycle stage 4
- Mandatory Primary Data
- product categorisation into sportswear or delicate based on the product label
- Mandatory Primary Data, If Available
- intrinsic quality and/or repairability data
- fibre fragment shedding inventory and impact data
- Mandatory Secondary Data
- applicable washing, ironing, and care scenario.
> Life Cycle Stage 5: End of Life
- Mandatory Primary Data
- share of unsold consumer products as an average of the last three administrative periods at the product sub-category level, if available; otherwise at the product level (i.e. apparel or footwear).
Further information on the source of the data can be found in the Q&A section.
How to leverage the Environmental Footprint (EF) database?
> Industry-partnership
The database is developed by data developers based on literature review and primary data from companies.
> European Database
The database is verified, validated, and managed by the European Commission and is the only fully EF compliant database.
> Status
EF 3.1 is valid until 31 December 2025. EF 4.0 is in development and expected in 2026 or 2027.
> Access
The EF 3.1 database is free to access with a finalised PEFCR.
