Product Environmental Footprint: what is it about?

The need to standardize the assessment of environmental impacts to facilitate the development of corporate strategies and the communication of sustainability is significantly influencing the market, which is increasingly looking for objective, verifiable and non-misleading data on the performance of products, processes or services.

For example, the Danish Ombudsman, within the "Quick Guide on environmental claims" established that, in the case of general claims such as "sustainable" or “environmentally friendly” not followed by explanations regarding such product characteristics, the company must be able to substantiate such generic statements through an analysis based on the life cycle of its products.

Furthermore, the Kering group has recently released the "Guidance for Sustainability Claims", contained within a more general document on sustainability, "Standards & guidance for sustainable production". Kering has established that the green claims of the companies that are part of the group must contain verified and proven information, through, for example, certifications, documentation relating to the percentage of recycled materials contained in the product, the report on the Product Environmental Footprint (PEF) and on the Product Carbon Footprint.

The methods for calculating the Environmental Footprint (EF) make it possible to measure and communicate the environmental performance of products and services (Product Environmental Footprint) and of organizations (Organization Environmental Footprint) during the entire life cycle based on methods internationally agreed scientifically valid assessment criteria.

The validity of these tools is confirmed by the European Commission, which considers the use of methods based on the environmental footprint as a way to corroborate and communicate environmental self-declarations thus demonstrating compliance with the more general rules on consumer protection.

In this article we will explore the Product Environmental Footprint (PEF), a particularly important methodology for the fashion industry to measure the environmental impact of products in the fashion sector and to support consumer decisions during the purchasing phase.

Product Environmental Footprint: definition and applications of the methodology

The Product Environmental Footrpint (PEF) is a methodology based on the life cycle assessment (LCA) which allows to quantify the environmental impact of products or services taking into account the activities of the supply chain, from the extraction of raw materials to the management of the end of life.

The PEF method is based on the life cycle approach and, in particular, on Life Cycle Thinking (LCT), which makes it possible to analyze the environmental, economic and social sustainability of products, services, technologies and systems considering all phases of the cycle of life, from raw material extraction to end-of-life management.

The LCT approach breaks away from traditional methodologies by not focusing exclusively on the assessment of the environmental impacts of the production process of a product but on the entire life cycle. This 360° view of the environmental impacts reduces the risk of focusing only on one phase of the asset's life and of shifting the environmental burdens from one phase to another without concretely solving the environmental criticalities identified.

The rules of the Product Environmental Footprint calculation method allow for perform PEF studies that are more reproducible, comparable, and verifiable than those conducted with other approaches. However, comparability of studies is only possible if the results are based on the same Product Environmental Footprint Category Rules (PEFCR).

The main objective of PEFCRs is to set a consistent and specific set of rules for calculate the relevant environmental information of products belonging to a specific category. These rules make it possible to facilitate comparisons and comparative statements between products belonging to the same category.

In 2019, the PEFCRs of the "T-shirt" product category were defined, valid until 31 December 2020.

Compliance with the PEFCR “T-shirt” was optional for internal PEF applications, while it was mandatory for external applications (e.g. communicating the results of a PEF study).

Requirements have been included in the PEFCR which allow the T-shirt to be distinguished from other types of products: the "T-shirt" product category includes clothing products suitable for dressing the upper part of the body, mainly consisting of a knitted fabric (i.e. at least 51% of product weight), with no full length (top to bottom) opening at the front. Knitted fabric is produced from circular or tubular knitwear with a gauge greater than 16 needles per inch and a surface density that is less than 270 g/m².

The threshold value of 51% on the weight of the knitted fabric compared to the weight of the product is used to differentiate T-shirts from other items composed of woven fabrics such as blouses and tunics. This data allows to facilitate comparative analyzes between the products included in the category "T-shirts".

Furthermore, according to the 2013/179/EU recommendation, the PEF methodology can be used for:

• Internal applications: support to environmental management, identification of environmental hotspots and improvement and monitoring of environmental performance with the aim of seizing opportunities for improvement and cost reduction;
• External applications (B2B/B2C): support for eco-design in all supply chains,    communication to the market (environmental labels, marketing, claims, etc.) of reliable and non-misleading data.

The phases of a Product Environmental Footprint study

In order to complete a PEF study in line with the provisions of the 2013/179/EU recommendation, the following phases must be completed:

• Define goals of Product Environmental Footprint study: in this phase the purposes and reasons for carrying out the study and the public to which it is intended are established;
• Define scope of Product Environmental Footprint study: in this phase the methodological choices are defined by establishing the exact unit of analysis, system boundaries, additional environmental and technical information, main hypotheses and limits. The unit of analysis for a PEF study is defined according to the following aspects: the function or service being studied: “WHAT” (e.g. medium size S, M, L t-shirt made of polyester), the entity of the function or service: "HOW MUCH" (for example a t-shirt), the expected quality level: "HOW WELL" (for example wear the t-shirt once a week and use the washing machine at 30 degrees for the washing) and the duration of the product life: "HOW LONG" (for example 5 years);
• Create the Resource Use and Emissions Profile: in this phase, an inventory of all input/output flows (energy, materials, water, emissions, etc.) related to the studied product or service is compiled;
• Environmental Footprint Impact Assessment: in this phase the previously recorded input/output flows are assigned to the relevant impact categories. Subsequently we proceed with the calculation of the extent of the contribution of each input/output flow to the respective impact categories by multiplying the values ​​of the flows by the relevant characterization factor for each impact category;
• Environmental Footprint Interpretation and Reporting: in this phase the results of the inventory and of the analysis of the environmental impacts are interpreted in order to draw conclusions and recommendations in order to encourage the improvement of the environmental performance of the product or service under study. The PEF report can then be drafted to provide a relevant, complete, consistent, accurate and transparent account of the study and calculated environmental impacts associated with the product.

Verification of the results of a Product Environmental Footprint study

According to Recommendation 2013/179/EU any PEF study intended for external communication (e.g. B2B or B2C) must be reviewed in order to ensure that:

• The methods used to conduct the PEF study are consistent with the guidance provided by Recommendation 2013/179/EU;
• The methods used to conduct the PEF study are scientifically and technically sound;
• The data used are appropriate, reasonable and meet the defined data quality requirements;
• The interpretation of the results highlights the identified limits;
• The study report is transparent, accurate and consistent.

Therefore, unless otherwise specified in relevant policy instruments, any study intended for external communication should be reviewed by at least one qualified and independent external reviewer (or review team).

The assessment of the verifier's or verification team's competencies is based on a points system that takes into account audit experience, PEF/LCA methodology and practice, and knowledge of technologies, processes or other activities relevant to the product under study.

The advantages for companies deriving from studies of the Environmental Footprint

The application of the EF methods, which include the Product Environmental Footprint and the Organization Environmental Footprint guarantee a series of internal and external benefits to companies, including:

• Alignment with EU policies which increasingly refers to the requirements of EF methods;
• Identification of the most impacting activities, materials or processes by identifying corrective actions capable of optimizing production processes;
• Identification of environmental risks along the supply chain and selection of suppliers more attentive to the issue of environmental sustainability;
• Improvement of corporate reputation and reduction of greenwashing risk;
• Customer loyalty thanks to transparent, clear and non-misleading corporate communication of the environmental performance of the product or organization;
• New financing opportunities, since banks and financial institutions are increasingly attentive to the environmental profile of organizations.

Criticality for the fashion sector

Despite the various benefits that EF methods and in particular the Product Environmental Footprint can offer companies, the PEF methodology presents several critical issues for the fashion sector.

In this regard, 12 NGOs (including Fashion Revolution, Fair Wear Foundation, Clean Clothes Campaign) have written an "Open letter on concerns about the PEF methodology and its application to apparel and footwear products" to the European Commission to put highlight some critical points of the methodology, such as:

• Poor data quality;
• Failure to consider the entire product life cycle;
• Failure to consider social impacts;
• Excessive focus on fibers obtained from recycled PET bottles which is a practice not in line with the circular model for PET bottles;
• The development of PEFCR for clothing and footwear is mainly led by representatives of industrial groups without involving civil society organisations;
• Poor effectiveness in “capturing” the non-physical durability (or emotional durability) of a product.

Furthermore, the Make The Label Count (MTLC) coalition which brings together various associations of producers of wool and other natural fibers has written a letter to the European Commission entitled "Ensuring EU textile legislation does not license greenwashing" in which it expresses concern about the validity of the claims greens that derive from the PEF methodology for the fashion sector as they may omit fundamental considerations for evaluating the impacts related to a product.

For this reason, according to the coalition it is necessary to include in the PEF a series of indicators to carry out an assessment of the release of microplastics, the plastic waste produced and circularity.

According to the coalition, the absence of such indicators could cause clothes made from synthetic materials to be shown as more sustainable than they really are.

Finally, EURATEX, the organization that represents textile and clothing manufacturers in Europe, also expressed its concerns in a position paper.

EURATEX has identified several key elements to foster the development of the PEF methodology among companies in the fashion sector:

• The use of PEF in sustainability claims must be voluntary and not mandatory;
• The use of robust, quality, verified data to conduct a PEF study;
• The absence of additional burdens for the use of the PEF methodology especially for SMEs;
• Periodic and regular verification of PEF studies which must be scientifically valid;
• The creation of a system accessible to all actors in the supply chain.

Conclusions

The Product Environmental Footprint represents a methodology that may be able to adequately respond to the market's request for clear, truthful and transparent information on the environmental performance of a product.

The EF methods related to the product or to the organization guarantee various internal benefits to companies in terms of optimization of production processes and a more rational use of resources, but also external benefits since they allow companies to communicate the environmental performance of the product or of the organization without incurring the risk of greenwashing.

Despite this, there are several limitations relating to the application of the PEF methodology in the fashion sector.

Recently, in fact, various organizations and coalitions have expressed perplexity regarding the methodology, emphasizing that further insights and clarifications are needed by the European Commission in order not to overlook factors or indicators that can influence the results of the evaluation of the environmental performance of a product.