Published by Christian Carron, PE | Embodied Carbon Solutions
The European Commission just gave the green light to comprehensive environmental impact rules that could reshape how companies measure and report product sustainability. In May 2025, the EU officially approved Product Environmental Footprint Category Rules (PEFCR) for apparel and footwear—marking a pivotal shift from simple carbon metrics to complex, multi-impact environmental assessment.
While the EU is still working through the technical details of emission factors for the newly approved environmental impact categories, this step forward signals where environmental assessment is heading. Companies that get ahead of this trend will be better positioned when these requirements become fully operational and expand to other product categories.
The question isn’t just about compliance—it’s about understanding the fundamental difference between Product Carbon Footprints (PCF) and Product Environmental Footprints (PEF), and what each approach can tell you about your products.
The Core Difference: Scope of Measurement
Product Carbon Footprint (PCF) focuses exclusively on greenhouse gas emissions throughout a product’s lifecycle. Think of it as a detailed carbon “receipt” that tracks CO₂ equivalent emissions from raw material extraction through manufacturing, transportation, use, and end-of-life disposal.
Product Environmental Footprint (PEF) takes a much broader view, measuring 16 different environmental impact categories including climate change, water use, land use, resource depletion, acidification, and toxicity effects. It’s like getting a comprehensive environmental health check rather than just a carbon reading.
When Each Approach Makes Sense
Choose PCF When:
- Carbon emissions is your primary concern
- You need straightforward metrics for abatement targets
- You’re responding to customer demands for carbon transparency
- You want to align with global climate initiatives like Science Based Targets
- You need quick, cost-effective environmental impact data
Choose PEF When:
- You’re selling into European markets (especially with upcoming regulations)
- You want to avoid “burden shifting” between different environmental impacts
- Your products have complex environmental profiles beyond just carbon
- You need comprehensive sustainability data for B2B customers
- You’re preparing for potential future regulatory requirements
Real-World Application Examples
A textile manufacturer using PCF analysis might discover that switching from conventional to recycled polyester reduces their carbon footprint by 35%. That’s valuable, actionable information that directly supports climate goals.
The same manufacturer using PEF analysis might find that while recycled polyester does reduce carbon emissions, it increases water consumption and chemical use in certain processing stages. This fuller picture helps them make more informed decisions about which suppliers to work with and what improvements to pursue.
The Business Implications
PCF offers simplicity and focus. The results are easier to communicate to customers and stakeholders. A single number—kilograms of CO₂ equivalent—tells a clear story that resonates with climate-conscious consumers and aligns with corporate carbon reduction commitments.
PEF provides depth and nuance. While more complex to interpret and communicate, it offers protection against unintended environmental consequences and provides a more complete foundation for sustainable product development.
Looking Ahead: Regulatory Landscape
The European Commission’s recent approval of PEF Category Rules for apparel and footwear signals a shift toward more comprehensive environmental assessment. Companies selling into European markets should expect PEF requirements to expand across additional product categories in the coming years.
Meanwhile, PCF methodologies continue to evolve and standardize globally, with initiatives like the Partnership for Carbon Transparency (PACT) making product-level carbon data more accessible and comparable across supply chains.
Making the Right Choice for Your Business
For most companies starting their environmental impact journey, PCF offers an accessible entry point that delivers meaningful insights without overwhelming complexity. It’s particularly valuable if your primary goals are carbon reduction and climate impact communication.
PEF makes sense when you need comprehensive environmental data for regulatory compliance, sophisticated B2B customers, or complex products where carbon alone doesn’t tell the full environmental story.
The good news? These approaches aren’t mutually exclusive. Many companies start with PCF to establish carbon baselines and then expand to PEF for products where broader environmental assessment adds strategic value.
Getting Started
Whether you choose PCF or PEF, the key is starting with clear objectives about what you want to achieve and who will use the information. Both methodologies require careful attention to data quality, supplier engagement, and proper methodology application to deliver reliable results.
The environmental impact of products isn’t going away as a business concern—it’s only becoming more important. Understanding the tools available to measure and communicate that impact is essential for any company serious about sustainability.
Need help determining which approach makes sense for your products? Embodied Carbon Solutions specializes in both PCF and PEF development, helping companies navigate the complexities of environmental impact assessment with practical, business-focused solutions.