Brands would stand to gain most from the proposed PEFCR (Product Environmental Footprint Category Rules) for apparel and footwear in Europe, but it would be manufacturers who would have to bear most of the burden by installing measurement and data acquisition devices to be able to acquire the data required for the process.
- The latest lot of concerns has been voiced by EURATEX, which reresents the European textiles and clothing industry and is a non-voting member of the PEFCR Technical Secretariat, which is developing the apparel & footwear PEFCR.
- EURATEX has released a position paper on the subject and called for improvements to the PEFCR process.
A 'Theoretical' Product: The position paper has argued that the current method has a rather theoretical approach.
- It considers all garment and footwear products available on the EU market, calculates averages and makes up a benchmark based on “average product”.
- The average product is a theoretical product, with no reference to an actual product in the market.
- It remains a major bottleneck to compare and assess the impact of real products, considering the complexity of the products available, the wide variety of processes involved, the number of stakeholders involved, the global spread of the supply chain and variety of clothing items.
The Existing Gaps: EURATEX has identified several key elements necessary to implement and recognise the full potential of the PEF methodology, as well as to break down the complexity of the term “sustainability” into distinct, understandable and clear building blocks:
- Optionality. Making environmental claims using PEF should remain voluntary.
- Accessibility. The process to develop a sector specific PEF needs to be fully transparent and easily accessible to all key value/supply chain actors, no matter the size.
- Level-playing field. Legislation fostering PEF must ensure a level-playing field, avoiding the proliferation of different methods in order to improve comparability and avoid unfair comparisons among materials/products.
- Robustness. For robust environmental claim, the use of PEF needs to relay on high quality and verified data. This is a continuous process to update and enlarge the database of materials, processes and products, and to avoid misleading results.
- Usability. SMEs shall be able to process the necessary data without extra burdens (expensive and inaccessible secondary data) and without having to overly depend on (non-EU) datasets owners.
- Verification. Sufficient transition period must be guaranteed, taking into account the impact on SMEs, for the purpose to verify the intended goal of PEF.
- Scientific. PEF needs to be scientifically sound and provide for a regular/periodic scientific and independent review.
- Flexible. The PEFCRs development process shall be open to new industries and product groups. The development timeline shall be flexible, with a continuously open call for applications and a more adaptable schedule.
PEF Alone Not Enough: EURATEX has argued that existing limitations can cause misleading results and information can lead to incorrect purchase decisions and wrong environmental strategies. It pointed out:
- The European Commission is preparing different policy measures, such as Ecodesign requirements for textiles (ESPR), mandatory green criteria for public procurement, EU Ecolabel scheme and measures to substantiate green claims.
- The PEF is visioned to support setting these policies, to improve comparability and prevent from greenwashing.
- However, the current single PEF score method is not able to make enough distinction and fulfill the requirements set in other EU policy measures.
