PEF and French Environmental Cost: What’s New for the Fashion Industry?

Two major announcements are reshaping how we measure and communicate environmental impact in the fashion sector. Both concern key methodologies now recognized at the national and European levels: the Product Environmental Footprint (PEF) and the French environmental cost.

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1. The PEFCR for Apparel and Footwear is Now Official

After five years of work and two public consultations, the European Commission has officially published the Product Environmental Footprint Category Rules (PEFCR) for apparel and footwear. These rules provide a harmonized framework to assess the environmental impact of textile and footwear products across Europe.

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2. The French Environmental Scoring System Gets the Green Light

On May 16, the French Ministry of Ecological Transition announced that the country’s environmental labelling scheme—based on the French environmental cost —was officially notified to the European Commission without opposition. This marks a major milestone for France’s national methodology.

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Key Takeaways in One Minute

• Two officially recognized methods: the PEF at the European level, and the French environmental cost for national implementation.
• First applications expected from 2025, when brands will be able to voluntarily display the French score on their products.
• A path toward convergence: despite different approaches, both aim to make environmental impact more transparent and comparable.
• A strategic signal for brands: environmental transparency is becoming a competitive advantage—and preparation starts now.

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What the Fashion Industry Should Expect Next

As EU regulations evolve, the PEF and the French environmental cost are shaping the future of impact measurement. Here’s how they differ—and what it means for fashion brands.

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1. Different Functional Units

Both systems account for product durability, but with distinct methodologies:

• The PEF measures impact per use, dividing total impact by the number of expected uses.
• The French score measures total impact over the full life cycle of the product.

In both cases, durability, whether intrinsic (material quality) or extrinsic (consumer habits), plays a central role.

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2. Different Databases, Different Impact Visions

The accuracy of environmental scoring depends on the data behind it:

• The PEF uses the EF 3.1 database, now enriched with textile-specific data.
• The French system relies on the Empreinte database, aligned with Ecoinvent and recently updated.

These choices significantly influence the results brands will report.

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3. Shared Logic, Diverging Priorities

Both methodologies deliver a single environmental score, based on the normalization and weighting of 16 impact indicators (e.g. climate change, eutrophication).

• Normalization expresses each impact relative to the average annual footprint of an individual.
• Weighting assigns different levels of importance to each category—but the weighting factors differ between the two methods.

France also introduced a specific correction for freshwater ecotoxicity, particularly relevant for representing the impact of organic cotton on biodiversity.

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4. Microfibers: A French-Specific Concern

In the French methodology, microfiber pollution significantly affects the final score—particularly penalizing synthetic garments.

In contrast, the PEF does not yet include microfiber emissions in the final score due to ongoing scientific debates. However, it requires that the impact be documented separately under the label "fiber fragment impact".

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5. Communication Rules

• In France, the voluntary environmental labelling scheme is nearing finalization, pending official decrees.
• At the EU level, the PEF remains a voluntary LCA method, usable for product communication if third-party verified.

Important note for French brands: any brand that communicates its PEF score in France must also provide the French environmental cost.

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Toward Harmonization: A Common Future

Despite current methodological differences, the long-term objective is clear: to harmonize environmental scoring and offer a reliable, unified framework that benefits both brands and consumers across Europe.

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The PEF in the European Regulatory Landscape

The PEF methodology is gaining traction thanks to several upcoming EU regulations:

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1. ESPR – Ecodesign for Sustainable Products Regulation

This regulation sets ecodesign requirements for products, including textiles, and introduces the Digital Product Passport (DPP). The PEF is mentioned as a reference method to evaluate environmental performance.

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2. CSRD – Corporate Sustainability Reporting Directive

Large companies are now required to disclose environmental impacts according to the ESRS standards. Although not explicitly required, the PEF is indirectly recommended as a life-cycle-based data source.

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Fairly Made Supports Brands Every Step of the Way

At Fairly Made, we’ve been involved in shaping both the French environmental cost and the PEF methodology from the beginning. We’ve participated in technical working groups, responded to public consultations, and actively contributed to building frameworks tailored to the fashion industry’s needs.

Our platform already integrates the French environmental cost, and we’re currently working to integrate the PEFCR rules. We help brands manage compliance, communicate strategically, and visualize their environmental impact.
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