Cascale’s Jeremy Lardeau joins policymakers in Madrid to examine PEFCR implementation, industry data readiness, and the collaboration needed to scale impact.
Following the European Commission’s approval of the Apparel & Footwear Product Environmental Footprint Category Rules (PEFCR) in 2025, industry leaders gathered in Madrid to explore what implementation will require in practice — and whether companies are ready.
Opening the session, Baptiste Carriere-Pradal, cofounder of 2B Policy, presented the foundations of the Apparel & Footwear PEFCR: a harmonized, science-based methodology built on Life Cycle Assessment (LCA). Structured around 16 environmental impact indicators, it enables brands to identify environmental hotspots across a product’s lifecycle. The methodology goes beyond carbon, incorporating durability, repairability, and duration of service, reinforcing a broader approach to product performance.
Moderated by Sónia Flotats, director of Move!, the panel that followed examined how the PEFCR connects to the evolving European regulatory framework.
Marina Prados Espínola, director at Policy Hub, framed the broader legislative landscape, noting that the Joint Research Centre (JRC) is conducting the Preparatory Study that will inform the Textile Delegated Act under the Ecodesign for Sustainable Products Regulation (ESPR). This study aims to define how environmental footprint information is measured and reported.
María Gonzalez-Torres, project officer at the European Commission, JRC, provided insight into the technical reasoning behind including footprint-based requirements alongside parameters such as durability and fiber composition. A footprint-based approach, she explained, allows regulators to capture impacts that single-attribute requirements alone may miss. The discussion also touched on comparative scoring approaches — assessing whether a product performs better or worse than the average — rather than relying solely on absolute values.
Bringing the industry perspective, Jeremy Lardeau, senior vice president of the Higg Index at Cascale, emphasized that the core challenge is no longer methodology, but implementation. While the PEFCR provides a strong scientific foundation, the real challenge lies in delivering the level of data and collaboration required to implement it meaningfully at scale.
A central theme of the discussion was the data availability challenge. While simplified footprint methodologies exist, they rely on minimal inputs and can miss supply chain complexity. The Apparel & Footwear PEFCR, by contrast, requires more granular product-level information, including detailed bills of materials and manufacturing data.
Many brands do not yet systematically collect or structure this data at the product level. Products are composed of multiple materials and components sourced across global supply chains, and much of the required information sits beyond a brand’s direct control. Meaningful implementation will require stronger data exchange and collaboration with manufacturers across tiers.
Lardeau highlighted the role of secondary databases in supporting Life Cycle Assessment. These datasets help fill primary data gaps and enable full product footprint calculations when supplier-level data is incomplete. However, they are not a substitute for improving primary data collection.
The conversation surfaced a key trade-off: precision versus scalability. More granular primary data improves accuracy but is harder to scale. Simplified approaches enable broader uptake, but risk losing nuance.
Ultimately, speakers agreed that footprint calculation alone will not drive transformation. The greatest opportunity for impact lies at the factory level, where improvements in energy use, material efficiency, and production practices can materially reduce environmental impact.
As Lardeau emphasized, one brand alone cannot shift the sector’s footprint. Long-term progress will depend on structured collaboration between brands and manufacturers, shared data, and tangible operational improvements.
The PEFCR defines what and how to measure. Turning that measurement into meaningful impact will depend on collective action.
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