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Last modified: January 31, 2018


The EU Environmental Footprint Initiative

How does the EU evaluate and compare the environmental impact of different products? To help answer this question, on April 9, 2013, the European Commission (EC) published the Communication “Building the Single Market for Green Products” accompanied by the Recommendation on the use of Product Environmental Footprint (PEF) and Organization Environmental Footprint (OEF) Common Methods to measure and communicate the life cycle environmental performance of products and organizations. Through these efforts, the EC is working to develop standards for measuring the environmental performance of products and organizations across all Member States (MS). By harmonizing existing measures, policymakers can help reduce confusion among consumers about environmental information, increase comparability among diverse products, and increase the readiness of consumers to invest in green products.

Development of the PEF Initiative

The PEF initiative was conceived after the EC concluded a study on Product Carbon Footprint methods. After analyzing existing methodologies, the study found that focusing solely on carbon emissions is problematic for many product categories because it would ignore other serious environmental impacts. Building on this finding, the EC resolved to pursue a more balanced approach to evaluating the environmental impact of products. Launched in 2011, the EC tested the new PEF guidelines through a pilot program with the goal of developing a harmonized footprinting methodology that accommodates environmental performance criteria. This program was limited to 10 participants and covered a variety of sectors, including agriculture. The results from this testing were used for the development of the final technical guide.

Rules of the Game

In addition to establishing the PEF methodology, the EC went a step further to write Product Environmental Footprint Category Rules (PEFCRs) and Organization Environmental Footprint Category Rules (OEFCRs) that provide guidance for specific product categories. PEFCRs are developed by the stakeholders in a sector through a consensus process. Originally tested in the paper sector, PEFCRs will increase both the consistency and reproducibility of PEF studies by setting clear performance benchmarks, monitoring communication between businesses and consumers, and promoting strong compliance and verification systems.

Pilot Program (2013 – 2017)

The EC launched a pilot program to test the development of PEFCRs and OEFCRs. In addition to industrial categories, this pilot program includes Beer, Dairy Products, Wine, Pasta, Feed, Meet, Pet Food, Olive Oil and Packed Water.

This wave of pilot programs was scheduled to conclude in December 2016 with the publication of final PEFCRs and OEFCRs but, due to some technical problems and to the complexity of the task, the end of the project is now scheduled for March 2018. Then, the European Commission will organize a Pilot Project Closing Conference, open to all stakeholders.

Looking Ahead

According to the Commission, PEF is voluntary and should not act as a restriction to international trade. However, PEF could become a trade barrier for some producers if they are made mandatory because it will require the replacement of internal LCA processes with those that emerge from the EU pilot programs. Switching, adopting or concurrently applying an EU approach would be very expensive for many companies and could negatively affect their competitiveness on the EU market.

It should also be noted that the European Food Sustainable Consumption and Production (SCP) ENVIFOOD Protocol will be fully compliant with the PEF methodology. Although the European Food SCP Round Table is an industry-driven initiative, the Commission remains a co-chair of the meetings.

USEU/FAS participates on the European Food SCP Round Table in Brussels and monitors the PEF pilot phase process closely as it may impact the competitiveness of U.S. companies if the PEF methodology becomes mandatory. After the pilots phase is completed in March 2018, the Commission will come up with a follow up document with different policy options. At this stage, it is unclear how the PEF results will be embedded in EU policies, such as environmental labeling and claims. If the Commission decides to come up with a legislative/non legislative proposal, it will most likely be before the end of 2018.