Unpacking the proposed textiles PEF: insights from industry experts

The European Commission is set to release further information on the Product Environmental Footprint (PEF) system during 2025. The textiles framework is designed to standardise how the environmental impacts of textile products are evaluated, PEF aims to bring consistency, transparency and simplicity to sustainability reporting across the relevant industry. By addressing long-standing inconsistencies and knowledge gaps, it seeks to benefit brands, consumers, and suppliers alike. But will it deliver on its promise, or could it disrupt existing efforts?

At its core, the PEF methodology seeks to harmonise the measurement of sustainability within the EU market. While adopting a lifecycle approach (similar to LCAs), it incorporates additional product-specific requirements. Each product category is governed by its own Product Environmental Footprint Category Rules (PEFCR), ensuring the framework reflects the distinct attributes of different goods. Using 16 environmental indicators, PEF offers a thorough assessment of a product’s environmental footprint and integrates these into a single score. These 16 indicators include Ozone Depletion, Human Toxicity (cancer effects), Human Toxicity (non-cancer effects), eco-toxicity to freshwater, particulate matter, photochemical ozone formation, acidification, eutrophication (terrestrial), eutrophication (aquatic freshwater), eutrophication (marine), land use, resource depletion (water), resource depletion (fossil fuels), resource depletion (minerals and metals), ionising radiation (human health) and climate change.

Developed by the Technical Secretariat, a multi-stakeholder working group open to public consultation, PEF ensures diverse perspectives are factored into decision-making. It also mandates both physical and digital labels to include sustainability criteria. By normalising data, assigning weights and aggregating indicators, PEF generates a comprehensive environmental score for products, enabling consumers to make informed choices and brands to improve practices.

Part of the Single Market for Green Products Initiative, this regulation complements a broader suite of forthcoming EU measures, including Digital Product Passports, Ecodesign for Susainable Products Regulation, Corporate Sustainability Reporting Directive, and Corporate Sustainability Due Diligence, among others.

In the ever-growing landscape of sustainability regulations, PEF promises to bring much-needed conformity. By offering a single, standardised methodology for evaluating environmental impacts, it seeks to replace the myriad different regulations and audits currently in place. As Saqib Sohail, responsible business lead at Artistic Milliners, notes, brands have often been “picking and choosing” environmental KPIs for their products from the 16 indicators, leading to inconsistencies. 

A universal standard could address several key challenges in the industry. For suppliers, it could help ease “audit fatigue” caused by a patchwork of data collection systems. For consumers, it could build trust in green claims by providing a consistent framework to interpret and compare these claims, with the PEF helping to level the playing field. Lastly, for brands uncertain about how to approach sustainability efforts and meet new reporting demands, including the CSRD, the PEF could serve as a guiding framework.

However, as with any new initiative, PEF faces both potential benefits and risks. While it could simplify compliance, a challenge lies in ensuring that the methodology is not too complex to be effectively implemented. If handled poorly and based in outdated data, PEF could add layers of bureaucracy that hinder innovation rather than driving meaningful progress.

One of the most promising aspects of the PEF initiative is its potential to accelerate better decision-making across the industry. Decathlon’s experience offers a glimpse into the value of such a system, having joined the PEF project launched by the European Commission back in 2013. Quentin Badonnel, head of environmental impact, says that by embracing the PEF’s indicators they Decathlon was able to collect a wider range of data points and bring more nuance into its decision-making. 

Consequently, Decathlon was able to evaluate over 95% of its turnover and identify the hotspots where it could reduce its environmental footprint more holistically. For instance, the company was able to focus on improving energy efficiency in dyeing processes and increasing the use of recycled materials. The company’s long-term goal is to expand the scope of sustainability efforts beyond apparel to products in other industries, such as ski equipment and sporting goods, demonstrating its utility.

In addition to better equipping decision-making, Badonnel highlights the opportunities of PEF data collection methods to assist compliance with other EU regulations. Decathlon’s work collecting a wide range of data points has been complementary with CSRD reporting, which requires double materiality. This concept mandates companies to evaluate how sustainability issues impact a company’s financial performance as well as considering the impact of business impacts on the environment and society.

Over time, more factors linked to circularity, durability and repairability will be included. Nienke Steen, CradletoCradle Products Innovation Institute’s global lead for apparel, textiles and footwear, highlights, how the PEFCR and Digital Product Passports will complement PEF LCA data to include more circularity data, like material source, circular design, durability, repairability and recyclability. That is important to take the use of non-renewable sources and end of life (or next life) options into consideration. She recommends starting from the 16 indicators and then improving the scope of our key indicators over time. At a time when the industry guidance can appear like patch-work, the PEF could offer a crucial starting point to assist with other regulations.

One such regulation is the European Commission’s Green Claims Directive, which is set to come into force in 2027, is one step toward holding companies accountable for their environmental assertions. With the rise of greenwashing, the need for clearer, more reliable information has never been greater. In this context, PEF could play a critical role in enhancing the accuracy of these claims and deliver meaningful comparison for consumers, promoting more responsible buying patterns in the future.

Although the consumers’ value-action gap (the discrepancy between stated values about sustainability and buying behaviour) has often been lamented, PwC consumer profiling shows that consumers are increasingly willing to pay a premium for sustainable goods. As climate change and environmental degradation increasingly affect people’s lives, the demand for trustworthy, eco-friendly products is likely to grow. The PEF system could help meet this demand by providing clearer, more consistent labelling – offering consumers the tools to make decisions aligned with their values.

Despite its potential, the PEF system carries notable risks. One primary concern is the cost and resource burden it may impose on businesses, especially small and medium-sized enterprises, as highlighted by Nienke Steen and Saqib Sohail. For suppliers producing thousands of products, conducting LCAs can be prohibitively time-consuming and expensive. 

Sohail cites Artistic Milliners’ experience, where gathering, collating and correlating data for a single LCA can take upto a full year when the whole supply chain from farm to finished goods are in the scope. SMEs, particularly in the global south, may struggle without sufficient support from larger brands to cover technology and manpower costs. Linked to this criticism is the composition of the guiding Technical Secretariat, which is primarily made up of large apparel and footwear brands all registered in Europe – although the final review and approval will be conducted by independent experts. 

There are also significant social implications. While PEF focuses on environmental factors, it risks sidelining social aspects critical to sustainable business practices. Sohail warns that increased compliance costs in a heavily regulated environment may lead to cost-cutting in areas not directly incentivised, such as wages and worker safety. This raises fears of a repeat of tragedies like Rana Plaza.

Data credibility presents another issue. As Quentin Badonnel emphasises, “environmental science is quite young; it requires continuous improvement,” particularly in addressing microfibre pollution. Peter Gorse—a Master's researcher at Cranfield University and designer of the Garment Facts Label—identifies microfibre pollution as the “Achilles’ heel” of textile production. Microfibre release is not currently accounted for in the Product Environmental Footprint (PEF), though the European Commission acknowledges its importance and includes it in the PEF Category Rules (PEFCR). Research into its environmental and chemical impacts is evolving but remains uncertain.

Further concerns arise from the oversimplification of complex production processes. Synthetic materials, for instance, often rely on EU production data that apply to only a minority of garments. Peter Gorse highlights the findings of a report from Plastchem showing that there are more plastic chemicals than previously known, and that while synthetic polymer production involves over 16,000 chemical types, only 6% of which are regulated. 

Gorse asks “How can you create a ‘score’ for a synthetic polymer? You are trying to score the unknown”. On the other hand, natural fibres such as wool can be unfairly penalised for land use, even when sheep are raised on brownfield sites unsuitable for agriculture.  Nienke Steen agrees, stressing the need to contextualise data and avoid generalised assumptions.

Gorse also questions whether PEF data is robust enough to provide accurate scores for consumers. To genuinely engage consumers and combat a throwaway culture, he advocates recognising the complexity of clothing. His work on the Garment Facts Label seeks to replicate the food industry’s nutritional labelling system, providing clear, detailed information. He insists any credible label must include data on the textile workers who make the garments.

As Steen points out, however, PEF’s primary focus has always been environmental and human health – not human rights. The EU’s CSDDD is expected to address these gaps, with updates anticipated during 2025. It ultimately all comes back to the intention and roll-out of the scheme.

PEF represents a promising step toward industry-wide alignment on sustainability goals across the textile industry, offering standardised, transparent data that could transform how businesses and consumers approach sustainability. It has the potential to serve as a recalibrating framework for the industry’s sustainability efforts. 

However, its success will hinge on thoughtful implementation across the supply chain, ensuring costs are manageable, particularly for SMEs, and that digital infrastructure can support its requirements. Furthermore, while data frameworks improve, relying on a single score risks oversimplifying complexities. 

Ultimately, as the data the industry collects improves and understanding of sustainability evolves, PEF could be the catalyst for a more sustainable future. Quentin Badonnel believes the PEF guidance and culture has a “continuous improvement mindset”, and hopefully the continuous refinement and a commitment to improving the regulatory and incentive system needed more broadly will be part of this.

 

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