Aligning the Higg Index Product Tools with Evolving Regulation

  • Legislation and Policy
  • Higg PM
  • Higg MSI
  • Higg Index Tools

In March, Cascale and Worldly held a webinar, “Navigating Legislation & the Higg Index: Higg Product Tools with PEF and more.” In this blog, we share the recording, highlight key takeaways, and address submitted questions during the session.

April 30, 2024

On March 27, Cascale and Worldly hosted the first webinar in a joint series called “Navigating Legislation & the Higg Index.”

The series is designed to showcase how the Higg Index aligns with evolving regulations and how the tools support users through regulatory compliance.

Speakers included Cascale’s Gabriele Ballero, policy and public affairs officer; Joel Mertens, director, Higg Product Tools; Elisabeth von Reitzenstein, senior director of policy and public affairs; Quinten Geleijnse, manager, Higg Product Tools and lifecycle assessments; and Worldly’s Paula Bernstein, senior data manager.

Over 160 attendees joined and raised many thoughtful questions about the future of compliance for consumer goods.

The next webinar in the series “Navigating Legislation & the Higg Index: Higg BRM with CSRD and more” will be held on June 12. Learn more and register.

Key Takeaways

Importance of Product Environmental Footprint (PEF)

“The PEF methodology is likely to play an important role in the future EU product and consumer law legislation. The Higg Product Tools methodology is well-positioned for alignment with Product Environmental Footprint (PEF)/PEF Category Rules (PEFCR), and the Higg Product Tools can support members in navigating evolving legislations and provide guidance in their compliance journeys.” –Elisabeth von Reitzenstein, senior director of policy and public affairs

France: One to Watch

“France has been, and probably will be for the foreseeable future, a frontrunner on sustainability legislation….The French label is based on a type of PEF. It has very strong alignment with the European Product Environmental Footprint principles. One difference on durability is that the French Methodology also includes ‘emotional durability’ to a more committed extent than the European one. This proves again that a common method on PEF is important…Another new French initiative is a draft bill targeting fast fashion and sometimes ultra-fast fashion… Also on the European level, France is fighting its corner on these issues. At a Council of the EU meeting on March 25, it called, alongside Sweden and Denmark, for an EU-wide export ban of hazardous textile waste to developing countries.” – Elisabeth von Reitzenstein, senior director of policy and public affairs

Synergistic Approach, Led by Data

“Through our partnership with Cascale, Worldly is paying close attention to this regulatory landscape and what our customers need in order to prepare and report on their sustainability performance and progress. My team meets at minimum weekly with Cascale to get deep into the weeds on PEF, how it’s evolving, and what it means for our tools and the solutions we’re delivering. The Cascale team also helps us understand the challenges the industry is facing firsthand and ways to address it in the tools. Data is going to play a critical role in many, if not all, of these reporting requirements.” – Paula Bernstein, senior data manager, Worldly

Accessibility is Key

“The concept of accessibility is really key for the Product Tools because we want a variety of users with different levels of LCA knowledge, as well as data availability to produce consistent environmental product footprint results.” – Quinten Geleijnse, manager, Higg Product Tools and lifecycle assessments

Going Beyond Compliance

“Like the rest of the Higg Index Tools, we don’t want the sole purpose of the tools to be compliance – the tools should be going beyond regulation. We’re not just trying to have a PEF-compliant calculator. That is not ambitious enough to get the industry on track to where it needs to be. [The Higg Index] needs to be aligned with PEF, at minimum for compliance, but we do need to go beyond that.” – Joel Mertens, director, Higg Product Tools

Similar, But Difference

“There are a lot of commonalities between Higg Index Product Tools, PEF, and France’s Ademe methodology but we do expect that even with the same product information, it is very likely you will have different results depending on which methodology you’re calculating to or which region you’re calculating to…One of the important things is while there are differences in the results, the impact categories, the data needs, there is a way to bring this all together, and that is the hub concept.” – Mertens

Study Up

“One of the key aspects here is the difference between a footprint calculation and a footprint study, or LCA study. Our tools are calculating an environmental footprint of a product. An LCA study is distinct from the footprint calculation. There are additional requirements that have to be done to take you to that full study level, including a report and verification.” – Mertens

Understanding PEF

“PEF is an implementation of ISO-1440 and 44 standards. There are study requirements associated with that that I think get lost in the narrative. As to other tools in this space, the one thing I will say right now is there is not a final PEFCR for apparel and footwear. There are a lot of claims and misunderstandings as to what you can say in terms of compliance to PEF and PEFCR, and there’s no such thing at this point.” – Mertens

Questions Answered

What sustainability regulations in the EU define requirements regarding the environmental impacts of my products?

On the webinar, speakers discussed relevant EU legislation and initiatives, including:

  • Corporate Sustainability Reporting Directive (CSRD) – [in force] – The CSRD is one of the ‘tools’ in the EU’s Green Deal toolkit, aimed to make the EU climate neutral by 2050. The CSRD establishes a standardized framework for companies to report on their social and environmental impacts through the use of European Sustainability Reporting Standards (ESRS).
  • Ecodesign for Sustainable Products Regulation (ESPR) – [expected mid-2027] – Designed to make sustainable products the norm in the EU, the ESPR sets eco-design requirements for specific product groups, including textiles. The requirements cover key sustainability aspects such as durability, recyclability, and use of recycled content, as well as the creation of a Digital Product Passport (DPP) that will act as a “digital twin” of the garments and aims at enhancing transparency and traceability along the value chain.
  • Substantiating Green Claims Directive (SGCD) – [expected 2025] – Aimed to tackle greenwashing, the SGCD introduces stricter and standardized methodologies for sustainability claims, making claims more reliable, transparent, and comparable.
  • France’s Anti-Waste for a Circular Economy Law – [in force] – The law requires large clothing brands to have verified environmental labeling; smaller companies will have to comply in 2024 and 2025.
  • France’s draft bill targeting fast fashion – [expected 2025] – The draft bill reinforces Extended Producer Responsibility (EPR) schemes for textiles by introducing a penalty for products that are not sustainable or recyclable. This addresses the fast fashion sector specifically.

What is the significance of PEF in relation to these regulations?

These regulations relate in different ways to the Product Environmental Footprint (PEF) method and product footprinting in general. CSRD requires a thorough assessment of an organization’s impacts, risks, and opportunities, and specifically mentions PEF as a way to assess these. In addition, the calculation of scope 3 emissions is required under ESRS E1, for which LCAs and/or PEF studies are useful. ESPR will likely require environmental impacts to be communicated to external stakeholders through the Digital Product Passport, for which PEF and LCA studies can be used. The European Commission proposal for the SGCD sees a more diminished role for PEF in its current form than initially foreseen. Although PEF might not become a mandatory requirement itself under SGCD,  the more simplified procedure now pursued may include a presumption of conformity for environmental claims that are based on recognized methods, such as PEF. The French labeling law is based on calculations obtained from a central database run by Ecobalyse and the Agency for Ecological Transition (ADEME). This method is inspired by PEF but has some noticeable differences.

What is the role of Cascale in drafting the Apparel and Footwear PEFCR?

The PEF category rules (PEFCR) contain specific rules for product categories that complement the PEF methodology. The rules direct focus to the parameters relevant to that specific product group, further standardizing the methodology. The Technical Secretariats (TS) of the EU develop these PEFCRs, and Cascale coordinates the TS developing the PEFCR for Apparel & Footwear, which includes determining the product-specific methodology and primary data requirements. The TS does not determine what secondary datasets are to be used and has to stay in line with the general PEF methodology. The PEFCR is expected to be finalized in Q1 of 2025 and is currently in its consultation phase.

How will the Higg Product Tools evolve to support users on their regulatory compliance journey?

The Higg Product Tools aim to guide product eco-design decisions by providing reliable, high-quality data. Given the legislative developments and the changing data requirements that they cause, the Product Tools should evolve accordingly. Our objective is to develop the Product Tools as a hub that allows different users (with different levels of data availability and LCA knowledge) to compute different types of results for different purposes. This means users can continue to identify impact hotspots and calculate scope 3 emissions, while we expand the tools’ functionalities to allow for PEF calculations. It is important to note that PEF compliance entails more than calculations only as PEF requires an extensive study report that has to be verified by a third party.

Some steps towards PEF-aligned calculations have already been taken by Cascale and Worldly. The current Product Module methodology was developed in alignment with the 2021 version of the PEFCR. This means the Product Tools are already well set up to expand towards PEF-aligned calculations. The team has mapped the key remaining differences between the current Product Tools methodology and emerging regulatory frameworks. This exercise informs Cascale’s product information Member Expert Team (MET) that currently helps define the product-relevant information fields the Product Tools need to contain to align with the data requirements of various frameworks, including PEF, ADEME, and the DPP. As indicated by the workstream flow chart below, Cascale will begin integrating the ADEME and PEF calculation methodologies with the Product Tools when they are finalized. In the meantime, work with the Product Information and Product Impact MET and continue to develop the tools’ hub functionality.

Cascale is working with Wordly to create a harmonized set of information fields for the Product Tools, containing all required information from the different legislative frameworks and distinguishing between mandatory, recommended, and optional data points. This allows users to compute different types of results based on a single set of information and enables the provision of at least some results when limited data is available. Cascale will also expand its current list of five impact categories to the 16 impact categories specified in the PEF methodology. To enable different result types to be computed, different calculation methodologies will have to be integrated into the Product Tools, some of which rely on different datasets than those currently used in the tools. Cascale is working together with Wordly to allow for parallel impact calculations and add these new (EF) datasets to the tools.

Please note that the visual is taken from the webinar slide deck and the timeline reflects the March 27, 2024 webinar date. Depending on when you are viewing this blog post, the visual may be out of date.

Will Cascale integrate the FEM with the Product Tools to allow facility information to be used for product footprinting?

Cascale and Worldly are working together to expand the Product Tools to enable users to select the energy mix used to manufacture their products. This will ensure the country or facility-specific energy mix is considered in the calculations, providing more precise impact calculations. A next step will be to connect the Higg Product Tools with the Higg Facility Environmental Module (FEM) to enable the sharing of facility data to be used for product impact calculations.

Will home goods, home textiles, and furniture be in the scope of PEF? 

While many of our members can and are already using the product tools for homeware and home textiles, PEF currently is explicit for “Apparel and Footwear.” The sectors the EU Commission has identified for PEF are the following:

  1. Apparel & Footwear
  2. Beverages
  3. Chemistry-based final products
  4. Construction products
  5. Electrical & electronics
  6. Food products (including products not for human consumption)
  7. Materials and intermediate products
  8. Energy production and transmission

However, the Product Tools may still be used to assess adjacent products such as home textiles. Even our current Product Module tool has an option for an “other” product category, which is being used by some members to assess these types of products.

Brooks Running

  • Brands & Retailers
  • Higg PM
  • Higg MSI

Read how this American-based performance athletic company uses Higg Product Tools to assess their environmental footprint.

Brooks Running logo
A running track with white lines and trees
November 10, 2023

“The Higg Product Tools empowered us to craft a sustainable strategy that aligns with our Planet 2030 commitments. With a solid understanding of the environmental footprint of materials and products across their life cycles, we are now equipped with data-driven insights to make informed decisions and realize our vision for a sustainable future. By leveraging these innovative tools, we’re not just running towards sustainability – we’re redefining the race.” 

— David Kemp, Director of Corporate Responsibility, Brooks Running


Brooks Running harnessed the power of the Higg Product Tools, including the Higg Materials Sustainability Index (MSI) and Higg Product Module (PM), to gain insights into its environmental impact and build strategies to achieve its climate and environmental commitments. The company used the tools to meticulously assess the impacts of both the raw materials (Tier 4) and processing stages (Tier 2 and 3) that contribute to its product ecosystem.

The Higg Index tools are fueled by collaboration. Brooks Running’s dedicated corporate responsibility team worked closely with suppliers to collect material-specific information – from composition and raw material type to dyeing and finishing methods. In instances where suppliers did not provide enough information, the team utilized the Higg MSI’s default values to ensure comprehensive coverage. Through this work, they were able to assess their environmental impact and identify which materials aligned best with their Planet 2030 commitments. The resulting reporting provided Brooks Running with a more accurate emissions factor for each material’s global warming potential, which was used to improve the accuracy of the company’s corporate Scope 3 Greenhouse Gas (GHG) Protocol emissions reporting.

In addition to their use of the Higg MSI, Brooks Running continued to scale its adoption of the Higg PM – entering footwear and apparel materials into the Higg MSI in order to evaluate the environmental impact of footwear and apparel styles through the Higg PM.

Sustainable Apparel Coalition Talks Data on GreenBiz x EDF Webcast

  • Higg Index Tools
  • Higg PM
  • Higg MSI
Photo of wind turbines in a green forested area
November 09, 2023

Joël Mertens, director Higg Product Tools Sustainable Apparel Coalition, joined a recent GreenBiz webcast sponsored by Environmental Defense Fund to discuss “How Circularity Can Help Advance Your Net Zero Strategy.” Hosted by Kori Goldberg, circular economy manager at GreenBiz, additional speakers included Andy Ruben, founder and executive director at Trove, Pete Edmunds, sustainability director at Deloitte, and EDF’s Thorfinn Stainforth, senior policy analyst at Environmental Defense Fund, and Elizabeth Strurcken, managing director.


The conversation was inspired by a new report from EDF and Deloitte, which outlines how companies can gain value and advance net-zero goals by transitioning to circular strategies – including reaching new markets and advancing climate outcomes.


After Sturcken introduced the report as the third in a collaborative series with Deloitte intended to help businesses make tangible progress towards their net-zero goals, Edmunds shared industry-specific circularity strategies for the textiles, packaging and automatic industries. He highlighted Lululemon’s plant-based nylon and the Loop reverse logistics programs, as well as the automotive industry’s shift to mobility as a service and battery reprocessing to meet demand from the growing EV market. Then, Ruben discussed a recent study on which Trove collaborated with Worldly, the exclusive licensee of the SAC’s Higg Index Tools, to determine the carbon savings of resale in comparison to rental and subscription.


Mertens emphasized the importance of pre-competitive collaboration in moving from commitment to action, stressing the success of this model in developing the Higg Index Tools. He shared that elements of circularity are embedded in the Higg Product Tools and provide a solid foundation for brands exploring circularity. However, he cautioned that brands should be careful about communicating circularity to consumers in the absence of impact measurements, as this can be construed as greenwashing.


Finally, Stainforth outlined circular policy developments in the EU, including their global impact, and three ways that companies can move faster and further on circularity.

Technical Review of the Higg MSI and Higg PM Tools

  • Higg PM
  • Higg MSI
  • Higg Index Tools

We are grateful to KPMG for their work in developing this report, which captures the invaluable insights and recommendations derived from the expert review of the Higg MSI and Higg PM tools.

September 26, 2023

Evolving for Change: Learnings and Action From the Technical Review of the Higg MSI and PM Tools

  • Higg MSI
  • Higg PM
Black and white headshot of Jeremy Lardeau
Jeremy Lardeau
September 26, 2023

The SAC was founded on the idea of evolution. Through ongoing updates, our tools become more and more powerful at helping our members transform their businesses. Today, we continue to demonstrate that core concept with the publication of the first report from our Higg Index Review process, which is downloadable here. The report addresses the Higg Product Tools – the Higg Materials Sustainability Index (MSI) and the Higg Product Module (PM) – and plays an important role in helping us reassess and evolve our product life cycle tools in order to best serve the industry. 

But change doesn’t happen in a vacuum: We had to listen and learn from you, our community. To do so, we engaged KPMG, which coordinated the creation of a panel of experts that represent a cross-section of the industry; KPMG led the process of generating the report, ensuring that it remained unbiased and independent. All who participated brought insightful perspectives that triggered powerful conversations about how we — the SAC, and the apparel and textile industry — can evolve the tools to drive greater impact. We were again reminded that our tools, while tailored to this industry, must respond to the global call to reduce social and environmental impacts as a whole and align with global industry standards. 

With a broad range of representation from the expert panel, we welcomed the strengths that were acknowledged, including the tools’ alignment with ISO LCA phases to quantify and assess the environmental impacts of materials and products. But more importantly, the review process surfaced clear feedback and recommendations to improve these tools. We are taking these recommendations to heart and we have started evaluating how best to address each recommendation. 

In some cases, the work is already underway. 

We are re-working the Higg MSI data structure and leveraging the forthcoming Higg Facility Environmental Module (FEM) update, which will launch in September, to connect them and allow factory-specific data to inform Higg MSI data sets, and which will lead to improved geographical coverage and specificity within the Higg Product Tools. We’re also actively working to improve data quality within our background datasets (secondary data), specifically in cotton fiber and textile wet processing data. Through this effort, we’re working with supply chain stakeholders to determine the type of data that is available, outline data gaps, identify intrinsic differences due to geography, and build consistent LCA models that can show improvements over time. This is a process that we’ll continue to replicate with other materials and processing stages in the future.

The expert panel also recommended that our tools must align with EU Product Environmental Footprint (PEF) – an evolving LCA methodology, that aims to create a harmonized common framework for calculating and communicating impact — and we fully agree. We’ve long incorporated alignment to the Apparel & Footwear PEFCR into our strategy goals and methodologies. For example: Our requirement on including renewable energy is aligned with PEF, as is our methodology to calculate the water impacts.

In other cases, we believe we can implement changes in the next phase of regular tool updates.

For example, we will develop the recommended signals and warnings, as well as offering more education and training, to help users correctly and more effectively use the tools. 

Finally, some recommendations will require a deeper process of stakeholder engagement and research to explore feasibility and practical application.

For example, the SAC is closely monitoring the progress made in ways to assess the full impacts of marine litter and microplastics in LCA data. Ultimately, the ongoing evolution of the tools means the SAC will continue to assess the recommendations over the coming months and how best to implement them in the tools’ development roadmap. 

In 2024, we will be conducting independent reviews for the Higg Brand and Retail Module (BRM) and Higg Facility Environmental Module (FEM) tools. Due to the timing of these updates, the Higg Product Tools were reviewed first. The remaining Higg Index Review reports will be shared in full by the SAC once they have been finalized by the review panels. 

Science isn’t static — and neither are we. We are committed to continued enhancement in order to arm the industry with the most robust, data-driven tools so that we can all stand behind decisions that are as socially responsible as they are environmentally sound. Finally, we are grateful for those who contributed their time and effort to the process of generating this report, as well as for the continued engagement of – and critical feedback from – our trusted members and partners.

Sustainable Apparel Coalition Presents on “Unlocking the Power of Packaging”

  • Higg PM
  • Higg Index Tools
Photo of Lee Green presenting
September 21, 2023

Lee Green, the SAC’s Senior Director of Marketing & Communications, recently presented on intersection between emerging policies and packaging at the “Unlocking the Power of Packaging: From Supply Chain Efficiency to Improved Sustainability” dinner hosted by Billerud, a paper and packaging materials company based in Sweden. The presentation also included remarks from the company’s Business Relationship Manager, Adam Sarama, and Global Commercial Director, Robert Testa, as well as a case study in packaging optimization presented by Maja Midebo, Senior Packaging Designer, and Johan Matsson, Manager of the EMEA & US Account Management Team, followed by interactive roundtable discussions.

Green began his presentation with the caveat that, when it comes to packaging and policy, the SAC’s Higg tools should not be seen as compliance checklists. The tools, which measure and score a company’s sustainability performance, should instead be seen as analytical frameworks, designed to provide actionable insights for continuous improvement on sustainable practices across the supply chain — including packaging. “Imagine you’re a sailor navigating treacherous waters without a compass — that’s what sustainability efforts are like without the Higg Index,” Green said. “The Higg tools provide a high-resolution map of your environmental and social impacts, helping to guide the journey toward sustainability. They’re more than tools; they’re your sustainability North Star.”

With that idea in mind, Green shared that the Higg Product Module (PM) does request information on packaging — its materials, reusability, and overall lifecycle — which can aid in determining a product’s overall environmental footprint. SAC Member brands like ALDO used the Higg PM to help commit to reducing the environmental impact of packaging through the use of post-consumer recycled materials in mailers, redesigning shoeboxes with handles to eliminate the need for additional bags, and utilizing 100% recycled materials for e-commerce shipping bags; similarly, Nike used analysis from the PM in developing its One Box packaging concept, which ships shoes in a shoebox, eliminating the need for an additional outer box and reducing packaging waste by 50%, bringing the company closer to its target of cutting waste by 10% per unit by 2025. However, Green emphasized that the tool generates analysis, rather than a compliance checklist. “While it can indicate whether your packaging strategy aligns with your sustainability goals, the Higg PM does not provide a roadmap to phase out, for example, single-use plastics,” he said. “Those initiatives need to be separately formulated, often requiring in-depth lifecycle assessments and material flow analyses.”

Green noted that the SAC’s view on regulations is that more stringent regulations can incentivize collective action. “While regulations can be seen as challenges,” he said, “We see them as opportunities — a catalyst for change. They demand that industry leaders embrace sustainable innovation, which leads to collective action, which is critical to the SAC’s mission of transforming the global consumer goods industry into one that gives more than it takes — to the planet and its people.”

As Green shared, the evolution of this idea is that out of collective action comes an ethos of shared responsibility and innovation. When it comes to packaging, Green said, “Regulations might set the rules, but they also open up a realm of possibilities for sustainable advancements in material science, design, and circular economy models related to packaging. This is where your expertise and willingness to collaborate can create industry-transforming solutions.”

Green shared how the SAC’s collective action mandate focuses on impact, not just compliance, helping members to understand regulations and their business impacts. And he described how the Higg Index tools and frameworks go beyond minimum requirements, helping members contribute positively to societal and environmental changes and providing a space where companies can collaborate and pool resources.

Finally, he closed by describing how the SAC is in a state of evolution, moving from isolated tools to holistic programs that address sustainability at scale, built on pillars like combating climate change, ensuring decent work, and creating a nature-positive future — which are all extremely relevant to packaging, given its flow in product lifecycle and waste management. “Data isn’t just a tool; it’s a compass,” Green said. “It directs us towards actionable goals and validates our journey, allowing us to participate constructively in policy dialogues and to fine-tune our practices to meet and exceed regulatory guidelines — making systemic change not just possible but inevitable.”