What is the PEF? And what is Cascale’s role in its development? Read below to find out more.

Footprint surrounded by flowers

About PEF

In support of future circular policies initiated by the European Commission, Cascale has been engaged by the Commission to convene a collaborative, multi-stakeholder secretariat, whose task is to develop Global Apparel and Footwear (PEFCR) which will serve as a policy standard for apparel and footwear products in the EU.

Our role in supporting the technical secretariat means we are not the sole creator of the PEFCR, but rather, we act as the facilitators of a collaborative conversation that is actively working to develop a Global Apparel and Footwear PEFCR.

By collaborating with policymakers, stakeholders, and our ecosystem partner Policy Hub – Circularity for Apparel & Footwear, Cascale’s past and future policy work acts as an important lever to facilitate industry change.

What is PEF?

The Product Environmental Footprint (PEF) is a Life Cycle Assessment (LCA) based method to quantify the relevant environmental impacts of products (goods or services). It builds on existing approaches and international standards, and is part of the “Single Market for Green Products Initiative” that is initiated by the European Commission.

The aim of the PEF is to create a common language and method for calculating a product’s environmental footprint, which is the foundation for a set of  specific rules. These rules are called the Product Environmental Footprint Category Rules (PEFCR), and are a common approach across the EU , normally created at an industry level.

The aim of the PEF is to set the basis for verified and trustworthy sustainability claims, in order to prevent greenwashing from companies.

It allows for better reproduction and comparability of results, but comparability is only possible if the results are based on the same rules, which is why the PEFCR exists.

EU policymakers are on their way to legislating the apparel and footwear sector on all aspects: from the design to the end-of-life of a textile product. The EU legislators know that a common methodology to assess the environmental performance of a product is key to ensure comparability and trustworthiness. Having this in mind, the Product Environmental Footprint (PEF) will become this reference method for companies – from small to large – that will place products on the EU market. This means that communication and marketing teams will very likely have to use the PEF to substantiate the green claims (e.g., carbon footprint) they make about products. Production teams would have to use the PEF to evaluate the durability of a product, in order to comply with future EU requirements. And compliance and finance teams would calculate eco-modulated fees of their products using the PEF method. Engaging in the development of the PEF methodology is therefore crucial to both Cascale and its members.

Bente Bauer, Policy Hub
Circularity for Apparel & Footwear

How Does a PEF Compare to an LCA?

The PEF only covers specific sets of impact categories.

The PEF method specifies requirements for all background data and currently has a central database to minimize differences that may occur due to modelling decisions.

To ensure scalability, the PEF will aim at defining the bare minimum one needs to create a meaningful yet comparable product footprint.

Overall, the PEF methodology has additional structure compared to a classic LCA. This helps allow for the type of approach that Cascale has been working towards, of scalable LCA results at a fraction of the cost.

What is Cascale’s Role in PEF?

Cascale supports the coordination of the technical secretariat around the PEF.  Developed under the leadership of the European Commission, the creation of the technical secretariat required more than 50% of the apparel and footwear sector to come together, and Cascale was uniquely positioned to convene brands, retailers, manufacturers, fiber associations and other important stakeholders to the table to meet this requirement.  Our role in supporting the technical secretariat means we are NOT the sole creator of the PEFCR, but rather, the facilitators of a collaborative conversation that is actively working to develop a Global Apparel and Footwear (PEFCR) which will serve as a policy standard for products in the EU.

This Technical Secretariat has developed a new form of partnership between public actors, private actors, and civil societies. The public sector’s role is to set and define the targets, boundaries, guidelines, final decisions, and hold the secretariat accountable to the latest scientific and academic developments. All other actors contribute their unique experiences and operations knowledge in order to merge the best of all worlds under democratic supervision

This unique setting will deliver a common method that Cascale looks forward to incorporating in its tools to accelerate standardization, and move towards the comparability of the environmental claims.

The goal of this collaboration is to co-develop specific rules for apparel and footwear that still meet the overall PEF methodology with industry stakeholders that are part of the secretariat.

The objective of our role is to ensure that the PEFCRs are scalable, drive change, and ultimately will reduce the impacts of the sector as a whole.

PEF organisational structure image

Why is Cascale Coordinating the Technical Secretariat?

Across the board, a key requirement for any group of organization to form a technical secretariat is their ability to gather at least 50% of any given industry. As an industry association with over a decade of experience working across apparel & footwear, the coalition was uniquely positioned to be able to aggregate such a group. We are grateful to be awarded the opportunity by the EU Commission to leverage the work we’ve done to further support our members and peers in their journey towards sustainability through a common approach for measuring and evaluating environmental impacts of apparel and footwear products.

As an organization, one of Cascale’s core objectives is to unite the industry around a common language in sustainability performance and measurement, which mirrors the goal of the PEF.

We believe the PEF is a key solution towards accelerating industry-wide alignment.

We also believe that good policy needs to build on these existing initiatives so we don’t create duplicity and add unnecessary burdens on actors in the global value chain. By building on what has already been done, we can accelerate the action we need to see in the next decade and all fronts from social through to environmental. The OECD and UNGP have been creating effective frameworks for years now, and in the case of Cascale, we have spent 10 years together with the industry developing effective tools, – legislation that does not build on these but goes off at tangents severely risks setting the industry back by a decade, which we cannot afford.

Finally, language is critical. We need unambiguous words and clear definitions. Just as Cascale spent the past decade developing tools for the standardized measurement of social and environmental impacts so we can compare apples to apples, policy needs to be written so that the language is clear cut across the board.

Well-informed and well-structured policy can help the industry comply quickly and accurately, which is one of the reasons we set up the Policy Hub together with GFA, FESI, and now joined by Textile Exchange & ZDHC to enable the industry to speak with one voice as it informs the development of regulation.

PEF participants logos

What are the Concrete Deliverables for the Technical Secretariat?

The creation of the Global Apparel and Footwear (PEFCR) aims to deliver a normalized cradle-to-grave LCA, a methodology that is IP-Free, which means that anyone can use it.

Users will not be expected to dive into the methodology, but instead, provide primary data for each product, such as the list of materials to create a product, fabric spinning technology, assembly time, use of ironing, etc. As the methodology gets finalized, it will list more data that you can use if you have them.

How Does Cascale Support its Members in Aligning with PEF?

Through a mix of membership requirements and tools that we provide, we are supporting our members in getting on the right track to prepare for this legislation. For example, one of our tools in the Higg Index, the Higg Product Module (PM), was developed using the European Footwear Draft PEFCR as a reference document, and Cascale plans to ensure that the Higg PM will align with other future regulations.

The new Higg PM, released in June 2021, enables assessment of a product’s impacts over its full life cycle through its end-of-use and offers companies insight into circularity opportunities within their sustainability programs. Measuring product impacts through the use and end of use life cycle stages will enable companies to better understand how their decisions support circularity. We have also launched new membership requirements for our members to follow and adhere to. A good example of this is the requirement for all Brands and Retailers to complete the Higg BRM – Brand & Retail Module, which has already been developed to align with the OECD Due Diligence Guidance for the Apparel & Footwear Sector, or to adopt the Higg FSLM, based on the SLCP Converged Framework to capture aligned Social & Labor data in supply chains.

Why is This Work Important to us at Cascale?

For our industry to be successful in solving systemic problems, fulfilling ambitious sustainability goals, and creating more respectful and secure work environments along the global value chain, we have to do this together, and to better know the impact of the product that we are putting on the market. That means everyone working in unison –– aligned around common data, insights, priorities, tools, resources, and programs ––will help us achieve these goals.

Cascale supports ambitious legislation because it will help us align around clear and common standards to create a consumer goods industry that gives more than it takes — to the planet and its people. We believe this policy can help further activate these priorities through alignment and implementation.