Investigation: EU's sustainable fashion score is 'finalised' but far from reliable

On paper, an agreement has been reached on the first tool for scoring fashion products on sustainability. The regulation comes from Brussels and is called the Product Environmental Footprint Category Rules (PEFCR), hereafter referred to as 'PEF', for apparel and footwear. However, the method and the way it was developed are a source of considerable concern for many.

The PEFCR is a method based on a life cycle assessment (LCA), intended to calculate the environmental footprint of different product categories (the 'CR' in PEFCR), such as apparel and footwear. The idea is that such a uniform standard makes comparing products on sustainability performance fairer and cheaper. A PEF calculation produces a single number, a single score. For now, it is intended for internal use only, not for marketing claims or on the clothing label. The European Commission (EC) primarily wants brands to learn to identify their own sustainability challenges and take action on them. The PEF can help with this, for example, by using the tool to compare designs made from different fabrics. Additionally, the PEF is intended to support legislation, such as the ESPR (ecodesign).

Thirteen product categories have been devised for the fashion PEF. To keep things simple, these are quite broadly defined (blazers and raincoats are one category). An average product was created for each category. This was based on extensive data from global databases on production steps and their effects on nature, the environment, and the health of the wearer (not the worker). Real products are weighed against these models using a calculator, which will soon be offered by various consultancies. How sustainably a fashion brand's 'real' product scores, therefore, depends heavily on the assumptions behind that calculation model, for instance, the assumed number of wears or raw material usage.

The score is calculated based on sixteen environmental impacts (such as CO₂ emissions, water use, and land use). The European Commission has determined the weighting of each component. Climate impact carries the most weight (approximately 21 percent), water use accounts for 8.5 percent, and land use for 7.9 percent.]

PEF is 'complete'

In the quiet before implementation, the question arises about the utility of a ranking system that is cheap and simple but yields no reliable conclusions. Karine Van Doorsselaer (University of Antwerp) warns: “I am very concerned about the value attached to LCA methodologies like the PEF. They are very rough estimates based on a staged scenario, generic data, and a thousand and one assumptions. These estimates do not account for ecodesign rules of thumb; principles of the circular economy; and technological evolutions such as the increased use of renewable energy. LCAs and the PEF are misleading companies and the government.”

The question for the industry seems to be: do we launch a flawed environmental measurement now, or do we wait for a method that experts are willing to defend, at the cost of precious time? The peculiar governance structure under which the PEF was developed points to the former: to do something quickly and just be done with it. As the steering committee itself says: our work is done. It is now up to the European Commission to label what constitutes sustainable fashion.

Strange governance

In May, the news broke: the final version of the PEFCR was greenlit. The PEF for apparel and footwear is complete. A storm erupted on LinkedIn. The PEF was said to be too lenient on fast fashion, outright unfair to natural fibres (except linen and hemp), blind to circularity, and developed under questionable governance. Others defend the method as a starting point: “Better something than nothing.”

In 2020, the EC decided a fashion PEF was needed. It was a latecomer in the series of PEFs for non-durable products, from potted plants to artificial turf. A steering committee, a Technical Secretariat (TS), was formed to lead the setup,along with a Swiss technical partner (Quantis) and a Netherlands-based chair (2B Policy). The EC observed but only funded 380,000 euros of the PEF from a Covid-19 emergency fund for climate action; it did not set aside a dedicated budget. In comparison, the PEF for the aerospace industry is funded with European money.

The non-profit Cascale calls itself the coordinator of the steering committee through its own channels, claiming to have been appointed by the European Commission (EC) in 2019. The EC refutes this in an email exchange with various press officers, stating: that was solely the decision of the fashion industry itself. Cascale's influence is visible in PEF 3.1, with references to its own research and the Higg product formula, a similar sustainability tool, that was caught greenwashing by Norwegian and Dutch regulators in 2022. In a telephone conversation, the chair of the TS emphasised that all decisions, including those on governance, were made by the members involved and not by a single party (Cascale).

EC keeps purse strings tight

Without a budget, there would be no PEF. Baptiste Carriere-Pradal, chair of the steering committee and founder of 2B Policy, faced a dilemma. The consultancy estimated the necessary investment to develop the methodology at one and a half million euros. Who was going to pay for it? Not Cascale, nor Euratex, the European industry association representing over two hundred thousand producers. Perhaps 2B Policy? “We are not an NGO,” states Carriere-Pradal.

2B Policy therefore devised a system of paying 'voting members' and observing 'non-voting members'. With ten parties willing to contribute 200,000 euros each (initially 150,000 euros and another 50,000 euros in 2024), there was enough money for a fashion PEF. More joined: organisations Alliance for European Flax-Linen & Hemp, Cotton Incorporated, W.L. Gore & Associates and fashion companies C&A, Decathlon, Fhcm, H&M, Inditex, Lacoste, Nike Inc, Refashion (Eco-Tlc), Sympatex, and VF Corporation. They paid for their say in the PEF. They voted on every decision where there was no consensus.

Non-voting members (non-payers) and other observers were, however, allowed to attend almost all meetings to share their candid opinions. “They also benefited from this approach to the PEF,” states Carriere-Pradal. Non-voting members included, for example, Ecos, Euratex, and the Camera Nazionale della Moda Italiana.

The Ministry of Infrastructure and Water Management (I&W) acted as an 'observer' in the PEF (as a non-voting member). Policy officer Marije Slump: “We joined late, but we pushed hard to ensure the single score is not communicated to consumers for the time being. That would give a very wrong impression of sustainable fashion.” According to Slump, I&W does support the principle of the PEF.

Parties outside the TS also had a say in the method. During the two public consultations in 2021 and 2024, over five thousand comments on the fashion PEF were received from more than 250 organisations. All comments have been answered, reports 2B Policy.

“Everyone who applied for the TS was admitted,” says the chair, pleased with the turnout. Three-quarters of the participants are headquartered in the EU, and the industry is broadly represented, from cotton farmers to civil society organisations, and from fast fashion to couture.

Disagreement

Disagreement arose later in the process, particularly from the natural fibres sector. Cotton and linen remained in the TS, but the fur, wool, and leather industries withdrew just before the finish line. “They don't want to put their name to the PEF, but they were involved the whole time,” says Carriere-Pradal. He calls it a political move. The wool sector's attitude, in particular, does not sit well with him. When the International Wool Textile Organisation (IWTO) hesitated to join, 2B Policy offered a discount of 90,000 euros. At that stage, representatives brought in a lot of important knowledge, says Carriere-Pradal. In 2024, the IWTO asked for a discount again; when that was refused, the wool sector, to his frustration, left the TS.

“Is it desirable for an industry to develop its own policy?” came a question from the audience during the PEFCR launch in Brussels in June. Many heads shook vigorously in disagreement. Among them was Luca Boniolo, sustainable textiles advisor at the Belgian NGO Ecos (a non-voting member). In an email, he explains why: “the system with paying members creates an incentive to see participation as an investment that needs to be recouped. It also carries the risk of maintaining the status quo, without real change. That is worrying, especially if the PEFCR does not remain a voluntary tool but becomes mandatory under other sustainability legislation.”

Polyester more sustainable than wool

The method the TS has now agreed to does indeed seem biased: only linen and hemp score better than synthetic materials. Synthetic materials like polyester, acrylic, and nylon perform better than natural materials like silk and cotton. And the big loser? Wool.

According to a calculation with a Glimpact PEF calculator (version 3.1), a standard polyester jumper has an 88.5 percent lower environmental impact than a comparable one made of wool. This difference is almost entirely due to the raw material: sheep use a lot of land and emit methane, which weighs heavily on the climate impact. The more hectares, the less sustainable the product. A wool jumper is also heavy, which results in higher scores for all environmental factors. Conversely, the negative effects of synthetic materials, such as microparticles and plastic waste, do not yet count towards the single score.

This calculation is for illustrative purposes only.

It is no wonder that the wool industry's trade association baulked at these figures. In 2021, natural fibre sectors like wool and cotton jointly launched a lobbying campaign: Make the Label Count (MtLC). Brands such as Devold, Marc O'Polo, and John Smedley advocated for a fairer PEF method.

According to Dalena White, secretary-general of the International Wool Textile Organisation (IWTO), there is a fundamental flaw in the current approach. “LCAs only measure negative impacts. Wool, therefore, gets no credit for biodegradability, carbon storage in grasslands, or biodiversity gains, while polyester is not penalised for pollution. This paints a very skewed picture of what is sustainable.”

She calls the data on wool in the EC's prescribed database ancient. “Calculations are based on twenty-year-old figures from New Zealand, from sheep bred for meat, which is not at all representative.” As long as the PEF works with such data, she argues, “wool will be structurally disadvantaged.” According to 2B Policy, that data is included in the final version of the PEFCR, which has not yet been published.

Dangerous assumptions

Criticism of the methodology shows that the PEF is not merely a calculator but also a reflection of the dominant beliefs within the industry. Experts from Febelsafe (the Belgian federation for protective clothing) and bAwear (a platform for textile LCAs) have compiled these assumptions in a position paper, including the points on regeneration and circularity from MtLC.

A key point of criticism is the strange way the PEF measures product lifespan. This is done using a 'multiplier' (IDM), which translates a product's quality into the number of wears. For example, a T-shirt that is typically worn 45 times can be adjusted in the calculator to between 30 and 75 times.

According to co-author and textile expert Anton Luiken, this is arbitrary: “A fast fashion T-shirt might only be worn five times in reality, whereas a thick wool coat can last a lifetime.” It makes no difference to the PEF whether the buyer of the winter coat lives in Greece or Sweden; nor does it matter what consumption behaviour is like in the brand's home market. This is impractical, finds Luiken, because “statistics show that people in, for example, Eastern Europe have less to spend, buy less, and use their clothes for much longer.”

There is also a multiplier for repairability: an extra button or a repair service from the brand earns bonus points. However, according to the authors, this is too simplistic an approach. It would be better to reward circular design directly, in anticipation of the law that requires it: ecodesign (Ecodesign for Sustainable Products Regulation; ESPR).

Mysterious chemistry

Luiken, a trained chemist, is particularly bothered by the casual way chemicals are handled. “We know very little about their role in the sustainability of apparel. A single chemical reaction can completely change the impact score. And we often don't know what suppliers do with wastewater.”

Jo van Landeghem, deputy secretary-general at Febelsafe and co-author of the aforementioned paper, adds that companies often keep their chemical compositions secret for intellectual property reasons, much like Coca-Cola with its mysterious recipe. “This means that the TS has either not properly understood this impact category or has made a lot of assumptions.”

The experts separately advise: remove chemistry from the PEF and use recognised standards for green, safe chemistry instead, such as Bluesign and ZDHC. Marielle Noto, responsible for partnerships at ZDHC, responds that she is critical of the PEF methodology but is glad that chemicals are part of it. “Otherwise, the topic would never be on the table.”

Frankenstein model

The fiercest criticism concerns the thirteen reference products (RPs) used by the PEF, phantom products with average values against which real products are measured. Among critics, the term 'Frankenstein model' has taken hold. For instance, a skirt and a jumpsuit are put in the same category, as are a blazer and a raincoat. “In the real world, there are huge differences in the composition and use of such products,” says Van Landeghem. “It would have been more meaningful to choose concrete reference products, like a standard cotton T-shirt. That is, unlike the Frankenstein model, common practice in CO₂ footprinting.”

Data jungle

Finally, data is another major headache. Firstly, the licence for the prescribed database expires this year, meaning fashion companies may have to purchase it themselves. Secondly, even experienced LCA experts barely understand how the database is structured. The vast amount of data was once collected from scientific papers and industry studies and verified by third parties. However, in well-known software programs like SimaPro and GaBi, the background reports are missing. This makes it unclear which processes, energy mix, and scenarios – best or worst case – are assumed.

According to LCA specialist Michela Sciarrone, it is impossible to fully comprehend all the information in the database. “Often, you only see the final results, the total scores for each impact category, measured in strange parameters like metals (phosphorus, chromium) and not in clear variables that I understand. Sometimes you come across very strange sources. [Such as a blog article: How to wax your shoes?, ed.]. You don't know if the measurements are up-to-date; you have to trust that it's roughly correct.”

Brands will soon be able to provide their own 'primary' data to override the default data. However, Sciarrone and Luijken think few will do so. They would rather opt for the 'secondary' data already in the system because it yields more favourable results, especially for fast fashion brands. The PEF allows this if collecting that data from suppliers is too complicated. Such a claim is easily made.

PEF to be revised

Although this PEFCR is now finalised, the broader PEF method is on the shelf in Brussels. A proposal is ready there with new impact factors such as biodiversity and microplastics and a better formula for circularity, which must be voted on by the EC. If this is approved, consideration will immediately be given to whether the single score for fashion can be released to the public after all, according to Elisabeth von Reitzenstein, a spokesperson for Cascale. Will the slow fashion jumpers from Joline Jolink and The Knitwit Stable, Knit-ted, and Maï, which are now considered 'slow fashion', then receive a label with a red colour code or the letter 'E'?

This article was translated to English using an AI tool.

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