The PEFCR (Product Environmental Footprint Category Rules) for apparel and footwear in Europe will give a limited and non-holistic picture of product impact, a joint statement issued by a group of 12 organisations has asserted.
- The PEFCR for apparel and footwear should not be used as a standalone method for underpinning labelling, green claims made in marketing, or any other EU policy measures announced as part of the EU Strategy for Sustainable and Circular Textiles, they said.
- The European Commission (EC) has said that the PEFCR would be considered in the context of developing criteria to substantiate and communicate environmental claims.
- The Commission is set to outline the role it sees for product comparison rules based on the PEF method in a legislative proposal on substantiating green claims, planned for release on 30 November.
Missing the Forest for the Trees: Simply adopting measures based on labelling and information provision to consumers alone will not be enough to achieve the objective set in the EU Textiles Strategy to reverse the overproduction and overconsumption of clothing by driving “fast fashion out of fashion”.
- As it was designed for product comparisons, the PEF method focuses on an individual product and does not look at absolute impacts from the sector as a whole.
The Higg MSI Context: The statement noted the recent ruling of the Norwegian Consumer Authority (NCA) that the global average data behind the Higg Materials Sustainability Index (MSI) did not constitute sufficient evidence for product-specific claims and that any claims made by companies building on this tool were seen by the NCA as misleading.
- The organisations have sought a clarification from the Commission as to whether there is any overlap between the secondary datasets and/or the methodology used by the Higg MSI and by the database which the Commission will provide for use with the PEFCR (the EF 3.1 database).
- In order to be verifiable and easily accessible, data used must be open access.
- The Commission was also urged to take up the LCAs necessary for true comparisons.
The Limitation Scope: The statement has flagged six areas of concern:
- Governance: The development of the PEFCR for apparel and footwear is mainly driven by representatives from industry groups. Civil society organisations are involved in a limited capacity as observers without voting rights, MEPs and Member State authorities are underrepresented in the process, and actors from the whole global value chain are not fairly represented (for example, small, local, craft-based industry, suppliers, manufacturers, and consumers).
- Poor data quality: The PEFCR are being developed by building on the comparison of data from different available lifecycle assessments (LCA). However, comparing LCA data can be problematic if the same boundaries and methods of allocation have not been used. Equally, it can be problematic if sample sizes are too small and unrepresentative and/or based on outdated or self-reported data. In addition, the PEF method is to a large extent based on the use of global average secondary data which fails to capture local variations in environmental impacts.
- Full product lifecycle not covered: LCA studies also do not fully capture the environmental impact of the product's whole life cycle. Highly toxic chemicals, such as PFAS, continue to play a major role in the production of textiles. Yet, the PEF method does not fully capture toxicity related to direct human exposure through the whole life cycle of the garment, including worker's exposure through manufacturing, use and waste treatment. The PEFCR for apparel and footwear contains no measurement of microplastic shedding. The impact of the textile sector on biodiversity as well as animal welfare are also not taken into account in the method.
- Social impacts not included: LCA studies tell nothing about the social conditions that a specific product was produced in (for example, whether workers received a living wage). There is also no consideration given to the socio-economic, cultural, and health impacts of recommending one fibre over another. Such a narrow view of product sustainability is not coherent with the EU’s own commitments to the Sustainable Development Goals (SDGs).
- Method overly rewards fibres made from recycled PET bottles: There is a risk that the method would give a bonus for recycling PET packaging into polyester fibres. However, the EU Textile Strategy identified that using recycled plastic polymers from sorted PET bottles poses a risk of misleading consumers and that such a practice is not in line with the circular model for PET bottles.
- Method doesn’t address fast fashion: The EU Textile Strategy draws a clear link between fast fashion and the growing use of fossil-based synthetic fibres. At the same time the PEF method has proved ineffective at capturing the non-physical durability (or ‘emotional’ durability) of a product, i.e. the idea that it is not only the physical properties of a product (such as fibre strength) that determine whether it will be used and worn for a long time; factors such as price and trend temporality play a role too. In this respect (and due to all lifecycle aspects not being covered as outlined above) there is a risk that the method favours the synthetic fibres which have driven overproduction.
Guide to the Subject: The European Environmental Bureau (EEB) has also published a guide for non-experts to navigate the PEF method and how it is being applied to apparel and footwear products.
- Titled Understanding the PEFCR for Apparel and Footwear: The Role of PEF in Policy, the documented was drafted by environmental consultancy Eunomia Research & Consulting.
The Signatories: The statement was signed by the following organisations:
- Changing Markets Foundation,
- Clean Clothes Campaign,
- Environmental Coalition on Standards (ECOS),
- European Environmental Bureau,
- Fair Trade,
- Fashion Revolution,
- Future in our Hands,
- IFOAM Organics Europe,
- Les Amis de la Terre France (Friends of the Earth – France),
- RREUSE,
- Umwelt Dachverband,
- ZERO.
