Summary:

• Development regarding the implementation of the Product Environmental Footprint Category Rules for Apparel and Footwear.‍
• Following the expiry of the EF 3.1 datasets at the end of 2025, it had become difficult, and in some cases impossible, to carry out EF-compliant studies or implement PEFCRs where the required EF-compliant datasets were no longer available.
• The European Commission has now published guidance addressing this issue in the context of the lower availability of EF-compliant datasets. (attached) This is a welcome and important clarification, as it provides a temporary way forward until the next EF database is available.

More information:

The Commission confirms that, where EF-compliant datasets are not available, users may rely on other secondary datasets, provided they follow the hierarchy set out in the guidance.

For studies carried out under a PEFCR or OEFSR, EF-compliant datasets should still be used where available. Where they are not available, they may be replaced by Entry Level ILCD-compliant datasets, preferably from a single unit process-based database.

Importantly, Technical Secretariats may identify the replacement datasets to be used and publish them through an annex or corrigendum to the relevant PEFCR/OEFSR. This would help preserve consistency and comparability across studies.

If no datasets are selected by the Technical Secretariat, users may select the relevant Entry Level ILCD-compliant datasets themselves, subject to clear reporting in the EF report and validation by verifiers.

The guidance also confirms that the validity of the relevant PEFCRs/OEFSRs is extended until the next EF database is in place, currently expected in 2028.

This means that compliance with the PEFCR for Apparel and Footwear becomes possible again, after several months of uncertainty. However, the guidance also makes clear that the use of non-EF compliant datasets may affect comparability of results, and that an appropriate disclaimer must be included in EF reports where such datasets are used.

The Technical Secretariat is also considering the option provided in the guidance to add an annex to the PEFCR listing the datasets to be used. This would be an important step to ensure that calculations remain as consistent and comparable as possible.

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