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Evaluation report Technical evaluation of the EU EF
pilot phase
2
Evaluation report Technical evaluation of the EU EF pilot phase
By: Annemarie Kerkhof and Wouter Terlouw (Ecofys)
Marisa Vieira (PRé Consultants)
Céline Alexandre and Remi Bagard (RDC Environment)
Date: April 2017
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Executive summary
Introduction
This evaluation report focuses on the technical content developed during the Environmental Footprint
(EF) pilot phase and takes the perspective of the Technical Helpdesk. During the EF pilot phase,
various sectors developed Product Environmental Footprint Category Rules (PEFCRs) or Organisation
Environmental Footprint Sector Rules (OEFSRs). The evaluation is based on the experience that the
Technical Helpdesk obtained in supporting the pilots and the European Commission (EC) during the
past three years (2013-2016).
The Technical Helpdesk has evaluated the progress and results of the EF pilot phase several times in
the past three years, and shared the findings with the EC during interim and final meetings and
reports. In this evaluation report, we evaluate the pilot phase in the period November 2013 –
December 2016, including previous findings when still relevant. The technical evaluation includes the
PEF Guidance 6.0, OEF Guidance 4.0 and some checks of the final draft PEFCR or OEFSR (submitted
to the EC at the latest by 31 January 2017). In the report, we also evaluate the simplification and
cost reduction of the availability of RP/RO models, SME tools and EF-compliant datasets which are
currently not finalised. Outside the scope of this report are the testing of communication vehicles, the
verification system, and the evaluation of the process of the pilot test.
We have developed a set of criteria to evaluate the EF pilot phase from a content perspective,
considering the following success indicators for the pilot phase defined by the EC at the start of the
pilot phase:
1. Number of pilots that manage to deliver a complete PEFCR/OEFSR
2. Demonstrate that the methodology works in any value chain
3. Simplification compared to conventional LCA
4. Reduced costs for companies for the environmental analysis
Evaluation results
Under leadership of the EC, the PEF and OEF methods have been extensively tested by 26 pilots in a
multi-stakeholder context in the past 3 years. During this period, an impressive number of technical
issues has been picked up and discussed with experts in the TAB meeting. Requirements were written
down in issue papers which have been integrated in the PEF Guidance 6.0 and OEF Guidance 4.0. The
consortium expects that such a rapid methodological development and improvement would not have
happened without the pilot phase and leadership of the Environmental Footprint team of the EC.
1. Number of pilots that manage to deliver a complete PEFCR/OEFSR
77% of all pilots submitted their final draft PEFCR/OEFSR to the EC by 31 January 2017. Since the EF
pilot phase is still ongoing, a final assessment of the completeness of the PEFCR/OEFSR was not
possible at the time of writing this report.
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2. Demonstrate that the methodology works in any value chain
The concept of PEFCRs and OEFSRs largely increases the harmonisation of PEF and OEF profiles, by
introducing the following elements:
Requirements for the Goal & Scope definition like functional unit and system boundaries
Data Needs Matrix
Requirements for modelling of common elements of product life cycles, like electricity and
disposal
Rules for modelling different life cycle stages
Default impact assessment categories and methods
It is expected that the current development of EF-compliant datasets and RP/RO models will further
increase the harmonisation of PEF/OEF profiles.
The increased harmonisation of the PEF/OEF profiles largely contributes to fair product comparisons.
A few methodological issues need further attention and improvement to ensure fair product
comparisons:
The scope of the product category, or subcategory, covered by the PEFCR is highly relevant
for fair product comparisons. The scope of the product category shall be defined by choosing
the functional unit at such a level that all competing products sold at the European market
that fulfil the same functional unit are included. The EC is currently working on a procedural
guideline on how to identify the relevant granularity level of product groups. This guideline
will complement the current requirements in the PEFCR Guidance 6.0.
The impact assessment of toxicity need to be robust enough to support product comparisons
and benchmarking. The impact assessment method USEtox and related characterisation
factors have its weaknesses which need to be addressed. The Joint Research Centre is
currently working on solutions regarding USEtox, including the development of
characterisation factors with alternative input data, and expanding the list of characterisation
factors in general.
The use and end-of-life stage of products should reflect the environmental performance of
products rather than differences in national conditions such as national electricity mix.
Every PEFCR/OEFSR includes a list of mandatory processes for which primary data shall be collected.
In addition to this, a company can differentiate the environmental performance of its product by
using company-specific data instead of default secondary datasets for the remaining processes in
situation 1/other processes, and in situation 2 in the Data Needs Matrix. This freedom however also
gives the company the possibility to choose the data options that deliver the best environmental
performance. Verification shall therefore play an important role here.
The OEF method was tested by only two pilots which has led to limited experience in using the OEF
method. The issues flagged by PEF pilots during the pilot phase are largely also relevant for the OEF
method. However, some OEF specific topics, like the definition of the representative organisation, did
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not receive special attention during the TAB. The pilot testing led to the insight that comparing
company‘s performance based on OEF studies is not useful.
3. Simplification compared to conventional LCA
The PEFCR/OEFSR development process during the pilot phase has been labour-intensive including
various iterations due to methodological improvements. We expect that the PEFCR/OEFSR
development process will take less time post pilot phase because the requirements for the
development of PEFCR/OEFSR will not change, at least not as frequently as during the pilot phase.
However, the development process will still require expertise in Life Cycle Assessment and knowledge
of the specific requirements of the PEF/OEF methods. However, once PEFCR/OEFSR are developed,
the time and expertise needed for creating PEF/OEF profiles is significantly reduced. It is expected
that the final PEFCR/OEFSR, developed during the pilot phase and which will be ready in October
2017, will have a great potential to simplify and reduce costs for conducting PEF/OEF studies,
compared to conventional LCA.
The main aspects that contribute to the success indicator of simplification compared to conventional
LCA are presented in the table below together with the benefit they bring.
Table i Overview of main aspects contributing to simplification compared to conventional LCA and resulting benefits.
Aspects Benefits
Existence of PEFCRs and OEFSRs compared to
conventional LCA or PCRs
Less expertise needed to conduct a PEF/OEF study
Materiality principle It simplifies PEF and OEF studies because data
collection is focused on hotspots, not on
unimportant processes
Background data and models available for use in
PEF and OEF studies
Only collection of foreground and activity data is
needed
Harmonization It avoids confusion and debate and thus lower
costs of conducting the PEF and OEF study.
4. Reduced costs for companies for the environmental analysis
This success indicator can only be evaluated once the final PEFCRs and OEFSRs are available for use
by companies. In this report, we have estimated the cost reduction for companies based on the
expected reduction in resources needed to conduct a PEF/OEF study.
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Reduction of costs mostly refers to time savings to perform a PEF/OEF study, and hence this success
indicator has a strong link with success indicator 3. The figure below gives an overview of the time
savings for conducting a PEF/OEF study depending on the guidance available for a sector.
PEFCR/OEFSR, RP/RO models and SME tools reduce the efforts for performing a PEF/OEF study by
providing guidance on goal and scope, data collection, modelling and life cycle impact assessment
and providing default data.
Figure i Reduced costs for companies for conducting a PEF/OEF study
In summary, the pilot phase has been a joint effort of the EC, pilot companies, involved stakeholders
and supporting parties. The PEF and OEF methods and the related PEFCR and OEFSR approach have
been strengthened in the past three years through the intense testing and immediate implementation
of lessons learnt in the PEFCR and OEFSR guidance documents. However, conclusions can only be
drawn when the EF pilot phase is finalised in October 2017.
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Table of contents
Table of contents 8
List of acronyms 9
1 Introduction 10
Scope of the evaluation 10
Success indicators and criteria evaluated 10
2 Evaluation results 12
Success indicator 1: Number of pilots that manage to deliver a complete PEFCR/OEFSR 12
Success indicator 2: Demonstrate that the methodology works in any value chain 13
Success indicator 3: Simplification compared to conventional LCA 20
Success indicator 4: Reduced costs for companies for the environmental analysis 23
Annex 1. List of technical issues 27
List of acronyms
EC European Commission
CFF Circular Footprint Formula
DNM Data Needs Matrix
DQR Data Quality Rating
EF Environmental Footprint
LCA Life Cycle Assessment
LCI Life Cycle Inventory
LCIA Life Cycle Impact Assessment
OEF Organisation Environmental Footprint
OEFSR Organisation Environmental Footprint Sector Rules
PEF Product Environmental Footprint
PEFCR Product Environmental Footprint Category Rules
RO Representative Organisation
RP Representative Product
SC Steering Committeee
SME Small and Medium Enterprises
TAB Technical Advisory Board
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1 Introduction
This evaluation report focuses on the content developed during the Environmental Footprint (EF) pilot
phase and takes the perspective of the Technical Helpdesk. During the EF pilot phase, various pilots
developed Product Environmental Footprint Category Rules (PEFCRs) or Organisation Environmental
Footprint Sector Rules (OEFSRs). The evaluation is based on the experience that the Technical
Helpdesk obtained in supporting these pilots and the European Commission (EC) during the past
three years. The experience comprises:
Ad-hoc support to pilots
Trainings (face-to-face trainings, webinars, e-learning modules)
Wiki development and maintenance
Technical support to EC (helicopter documents and technical issue papers, for instance on use
phase, biodiversity, electricity modelling, etc.)
Participation in Technical Advisory Board (TAB) meetings
Review of second draft PEFCRs/OEFSRs
Chairing three workshops for the Circular Footprint Formula (CFF)
Scope of the evaluation
The Technical Helpdesk has evaluated the progress and results of the pilot test several times in the
past three years, and shared the findings with the EC during interim and final meetings and reports.
In this evaluation report, we evaluate the pilot test in the period November 2013 – December 2016,
including previous findings when still relevant.
It must be mentioned here that the EC has prolonged the pilot phase to November 2017. The
extended period will mainly be used to remodel the PEFCR/OEFSR models developed by the 24 pilots
using data acquired by the EC, which will result in updated PEFCRs/OEFSRs in October 2017.
Consequently, we were not able to evaluate the pilot phase in its entirety.
The evaluation includes the PEF Guidance 6.0 and some checks of the final draft PEFCR or OEFSR
(submitted to DG Environment at the latest by 31 January 2017). We also evaluate the simplification
and cost reduction that may be realised by the availability of RP/RO models, SME tools and EF-
compliant datasets which are currently not finalised. Outside the scope of this report are the testing
of communication vehicles, the verification system, and the evaluation of the process of the pilot test.
Success indicators and criteria evaluated
We have developed a set of criteria to evaluate the pilot phase from a content perspective, taking
into account the following success indicators:
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1. Number of pilots that manage to deliver a complete PEFCR/OEFSR
2. Demonstrate that the methodology works in any value chain
3. Simplification compared to conventional LCA
4. Reduced costs for companies for the environmental analysis (compared to LCA)
Table 1 shows the criteria for evaluating the pilot phase from a content perspective.
Table 1. Criteria for evaluation.
Success factors Criteria
Number of pilots that manage to
deliver a complete PEFCR/OEFSR
A. Final draft PEFCR/OEFSR submitted to DG Environment
by 21 December 2016 or 31 January 2017
B. Completeness of PEFCR/OEFSR
Demonstrate that the methodology
works in any value chain
A. Harmonised method within product category/sector
B. PEFCR support fair comparison of products within the
same product category (same functional unit)
C. PEFCR/OEFSR enables product/organisation
improvements from an environmental point of view
Simplification compared to
conventional LCA
A. Existence of PEFCR/OEFSR simplifies compared to
conventional LCA or PCRs
B. Materiality principle simplifies PEF and OEF studies
C. Background data and models available for use in PEF
and OEF studies
D. Harmonization
Reduced costs for companies for the
environmental analysis
A. Reduced resources for a sector working together to
develop a PEFCR/OEFSR
B. Reduced resources for companies when a PEFCR/OEFSR
is available
C. PEFCR/OEFSR includes secondary data for all processes
D. SME tool is available
E. RPs and ROs models are available
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2 Evaluation results
Success indicator 1: Number of pilots that manage to deliver a complete PEFCR/OEFSR
Summary of findings
77% of all pilots submitted their final draft PEFCR/OEFSR to the EC by 31 January 2017. Since the EF
pilot phase is still ongoing, a final assessment of the completeness of the PEFCR/OEFSR was not
possible at the time of writing this report.
Detailed findings per criterion
1A. Final draft PEFCR submitted to SC by 21 December 2016 or 31 January 2017
Out of 26 pilots, 16 submitted their PEFCR/OEFSR to the EC by 21 December 2016 (62%), and an
additional 4 pilots submitted their PEFCR/OEFSR to the EC by 31 January 2017 (77%). Two pilots
were discontinued in 2016, the remaining four pilots have been delayed.
Two pilots were discontinued during the EF pilot phase:
Marine fish pilot was discontinued in June 2016. The pilot released a draft screening report and
a file consolidating comments from public consultations. These documents were endorsed by the
TS for marine fish. The TS for marine fish communicated the main reasons for not finalising the
PEFCR during the Steering Committee in June 2016, which are the following:
o Timing issue to finish the work within the foreseen timeline;
o Lack of background data regarding marine fish products, which makes it extremely
complicated to carry out a PEF study for products sourcing marine ingredients from
different parts of the world;
o Limited representativeness of the sector in the TS.
Coffee pilot was discontinued in October 2016. The pilot released a draft PEFCR, but this
document has not been officially endorsed by the TS for coffee. In a call with the Helpdesk, the
TS coordinator of the coffee pilot gave the following main reason for not finalising the PEFCR.
There was a fundamental disagreement in the choice of representative products among
stakeholders. The disagreement stems from a different understanding of the basis for product
comparison. All coffee can be compared or the coffee can be compared within one defined
technology (in this case a specific brewing method). It seems that the choice of the
representative products (benchmark) in this case can lead to different competitive advantages.
The stakeholders within the coffee pilot could not reach an agreement on this.
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1B. Completeness of PEFCRs/OEFSRs
Since the EF pilot phase is still ongoing, a final assessment of the completeness of the PEFCR/OEFSR
was not possible at the time of writing this report. The review of final PEFCR/OEFSR by the review
panels can indicate the completeness of the final PEFCR/OEFSR at the end of the EF pilot phase in
October 2017.
Success indicator 2: Demonstrate that the methodology works in any value chain
Summary of findings
The concept of PEFCRs and OEFSRs largely increases the harmonisation of PEF/OEF profiles, by
introducing the following elements:
Requirements for the Goal & Scope definition like functional unit and system boundaries
Data Needs Matrix
Requirements for modelling of common elements of product life cycles, like electricity and
disposal
Rules for modelling different life cycle stages
Default impact assessment categories and methods
It is expected that current development of EF-compliant datasets and RP/RO models will further
increase the harmonisation of PEF/OEF profiles.
The increased harmonisation of the PEF/OEF profiles largely contribute to fair product comparisons. A
few methodological issues need further attention and improvement to ensure fair product
comparisons:
The scope of the product category, or subcategory, covered by the PEFCR is highly relevant
for fair product comparisons. The scope of the product category shall be defined by choosing
the functional unit at such a level that all competing products sold at the European market
that fulfil the same functional unit are included. The EC is currently working on a procedural
guideline on how to identify the relevant granularity level of product groups. This guideline
will complement the current requirements in the PEFCR Guidance 6.0.
The impact assessment of toxicity need to be robust enough to support product comparisons
and benchmarking. The impact assessment method USEtox has its weaknesses which need to
be addressed. The Joint Research Centre is currently working on solutions regarding USEtox,
including the development of characterisation factors with alternative input data, and
expanding the list of characterisation factors in general.
The use and end-of-life stage of products should reflect the environmental performance of
products rather than differences in national conditions such as national electricity mix.
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Every PEFCR/OEFSR includes a list of mandatory processes for which primary data shall be collected.
In addition to this, a company can differentiate the environmental performance of its product by
using company-specific data instead of default secondary datasets for the remaining processes in
situation 1/other processes, and in situation 2 in the Data Needs Matrix. This freedom however also
gives the company the possibility to choose the data options that deliver the best environmental
performance. Verification shall therefore play an important role here.
The OEF method was tested by only two pilots which has led to limited experience in using the OEF
method. The issues flagged by PEF pilots during the pilot phase are largely also relevant for the OEF
method. However, some OEF specific topics, like the definition of the representative organisation, did
not receive special attention during the TAB. The pilot testing led to the insight that comparing
company‘s performance based on OEF studies is not useful.
Detailed findings per criterion
2A. Harmonised method within product category/sector
During the extensive testing of the PEF and OEF methods during the pilot phase, it became clear that
the methods could be improved on several aspects. Under leadership of the EC, an impressive
number of technical issues (see Annex 1) has been picked up and discussed with experts in the TAB
meeting. Requirements were written down in issue papers which have been integrated in the PEF
Guidance 6.0. The consortium expects that such a rapid development of methodological
harmonisation would not have happened without the EF pilot phase and leadership of the
Environmental Footprint team of the EC. On the other hand, the continuous methodological
improvements created a substantial amount of work for the pilot TS. A more streamlined process with
less methodological improvements would have saved resources for the pilot TS, but it would not have
led to the same degree of methodological robustness.
Goal & Scope definition: PEFCR/OEFSR define the key elements from the goal and scope definition:
functional unit, system boundaries, Life Cycle Impact Assessment (LCIA) methodology, types and
source of data, data quality requirements, and allocation rules. This increases the harmonisation of
PEF/OEF profile results.
Data needs matrix: The use of company-specific and secondary data was flagged as an issue early
in the pilot phase and was under discussion for quite some time. When different secondary datasets
or company-specific data of different quality are used to create PEF profiles within the same product
category, the results can differ. These differences do not necessarily reflect the differences in the
environmental performance of products, but can be the result of the use of different data. The EC has
taken a deep dive into this topic and has dealt with it in a very constructive way. The data needs
matrix has been developed with various experts, including experts from the Helpdesk and the TAB.
The data needs matrix is a novel approach and provides detailed requirements on which data shall be
used in which situation. The “materiality principle” and the “influence of the company to obtain data”
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are integrated in this matrix in a structured way. The data needs matrix enhanced the harmonisation
of the PEF/OEF method tremendously.
Since the data needs matrix was introduced quite late in the pilot phase (discussed on the TAB
meeting in May 2015), it was applied to the pilots in a phased manner, depending on the progress of
each pilot. The data needs matrix is implemented by all pilots in the final draft PEFCR, but
implementation is not always in line with the PEFCR Guidance 6.0. The extent in which the data
needs matrix is implemented in the final draft PEFCRs varies largely per pilot.
Modelling of common elements in product life cycles: Product life cycles often include common
elements such as electricity, transport, packaging, and disposal. When these elements are modelled
in an inconsistent way, this can lead to double-counting or not counted impacts. The EC has picked
up this issue via working groups and issue papers addressing cross-cutting issues.
In 2014, the EC started the cattle model working group to ensure consistency in modelling cattle as a
common element of several PEF pilots: dairy, meat, leather, feed and pet food. The working group
had to come up with a common cattle model. Due to a lack of consensus, the JRC finally developed
one harmonised approach that has been applied during the pilot phase. The approach is however still
under debate and that is the reason why this section has not yet been included in the updated
version of the PEF Guidance and for delay in the delivery of the PEFCR for red meat products.
The packaging working group started in 2015 aiming at providing guidance on packaging related
modelling, including data issues, transport and end-of-life issues like re-use and recycling (PEF
Guidance 6.0, section 2.12). All the work aimed at ensuring consistency of packaging modelling
across pilots. Key topics covered were:
The definition of a list of background datasets to provide to pilots in order to model all the
packaging.
Work on the recycling rates values to be considered for the packaging at EU level and at
country level. This work ensures that all PEF studies will refer to the same source, unless a
more specific value is given within the PEFCR.
Rules to assess the average number of use or reusable packaging
One key point not covered within the packaging working group is the function of the packaging and
its influence on the rest of the life cycle, e.g. the shelf life. This issue is hardly addressed by any of
the pilots.
Throughout the pilot phase various End-of-Life formulae were tested by the pilots. In addition, three
workshops were organised in 2016 to discuss the End-of-Life (EoL) formula, later rephrased to the
Circular Footprint Formula (CFF), as included in Annex V of the PEF Guide (2013), and to find
alternative solutions. Multiple stakeholders participated in these workshops to discuss alternatives for
the formula. All stakeholders agreed on the need to develop a single formula but had different views
on some choices. The final requirements are included in the PEF Guidance (PEF Guidance 6.1, section
2.14).
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The Circular Footprint Formula (CFF) has three important improvements over the original End-of-Life
formula provided in the PEF Guide (2013):
The CFF introduces allocation factors for recycling and energy recovery to better reflect
market situations.
The CFF takes into account the quality of both the ingoing and outgoing recycled materials
instead of only the outgoing recycled materials.
The CFF includes specific parameters for heat recovery and electricity recovery instead of for
energy recovery in general.
These improvements were made because, amongst others, the original formula favoured the
incineration with energy recovery above recycling, due to the allocation of recycling benefits between
the life cycle that produces the recycled material and the life cycle that uses the recycled material
while the benefits of energy recovery were entirely allocated to the life cycle that sends material to
incineration. With the improved formula this issue is covered.
Other common elements were dealt with via issue papers and discussed in the TAB, including
agricultural processes (pesticide and fertilizer use and application), electricity, transport, and the use
stage.
The consistency of common elements in product life cycles may even be enhanced with the use of the
EF-compliant data purchased by the EC, because the modelling as well as data will then be consistent
for these processes.
Impact assessment: The PEF/OEF Guide (2013) specifies which impact categories shall be assessed
and which impact assessment methods shall be used for this. This is a major difference with LCA
standards like ISO 14044 where this is not made explicit. The specification leads to a more
harmonised method. However, critical comments were made that biodiversity was not included in the
default set of impact categories. Biodiversity is an endpoint indicator in LCA while all default impact
categories included in the PEF Guide are midpoint indicators. Biodiversity is therefore indirectly
addressed through these midpoint indicators. However, in some cases the method did not report
biodiversity as a hotspot, while it should have, like in the use of forests for paper. This resulted in
strong reactions from WWF and EEB and the paper industry, who were already investing much to
address this topic. An issue paper was written on how to address biodiversity in PEFCR/OEFSR. Pilot
TS could include biodiversity as a most relevant impact category in the PEFCR section “Additional
environmental information”, unless it can make clear it is not an issue. However, in practice very little
will be done with this information, as it does not influence the PEF/OEF profile score.
During the pilot phase, the impact assessment methods have been discussed and criticised a number
of times. The main concerns related to:
Mismatch between LCI and LCIA. The data in existing datasets do not always match the data
needed for some impact assessment methods. This was for example the case for land use. This
problem will be solved with the development of new EF-compliant datasets.
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Maturity of LCIA methods for certain impact categories was questioned during the pilot phase.
Therefore, the Joint Research Centre reassessed existing default LCIA models as included in the
PEF/OEF Guide that were considered as less robust or up-to-date and made suggestions for
necessary updates1, using the same criteria, and a few additional ones, as defined in the ILCD
Handbook2. The impact assessment methods of the following impact categories have been
discussed during the pilot phase and will be updated in the PEFCR Guidance: particulate matter,
land use, water scarcity, resource use (minerals), and resource use (energy carriers).
The impact assessment method for toxicity, USEtox, was criticized by pilot testers. The EC
therefore organised a workshop on the USEtox method at 15 January 2015 with the aim to gather
feedback from pilots on the use of USEtox in the screening study. From the workshop it became
clear that the model itself was not criticized as such but the input / output data were seen as
doubtful. USEtox was perceived as not robust enough for benchmarking and communication
purposes. This problem is not specific for the PEF/OEF method, but affects the pilots where
toxicity is one of the most relevant impact categories, e.g. copper production, decorative paints,
liquid washing detergents and PV electricity generation. This affects the product group chemistry-
driven products in general. The Joint Research Centre is currently working on solutions regarding
USEtox, including the development of characterisation factors with alternative input data, and
expanding the list of characterisation factors in general. JRC presented its approach in the TAB
meeting of March 2017.
2B. PEFCR support fair comparison of products within the same product category
This criterion assesses to what extent the PEF method supports comparability of PEF profiles. This
criterion is closely related to the criterion of harmonisation (2A), but focuses on elements of the
method that are of specific interest for the comparability of PEF profiles.
EF-compliant datasets: The major methodological improvements realised during the pilot phase
largely contribute to the harmonisation of PEF/OEF profiles which supports fair product comparisons.
The EF methodological requirements will be used consistently in the EF-compliant datasets which will
further increase the harmonisation of PEF/OEF profiles, strengthening the basis for fair product
comparisons even further.
Granularity: Granularity refers to the scope of the product category or subcategories covered by a
PEFCR. The scope of the product categories of the current PEFCRs is sometimes too narrow and
sometimes too broad which prohibits the comparison of products that compete at the same
commercial market. Moreover, the PEFCR development process can become difficult to manage in the
future when the scope of many PEFCRs is narrow, because a high number of PEFCRs may need to be
developed. Examples of developed PEFCRs with a narrow scope are: PV electricity (other electricity
generation technologies could have been included), and liquid washing detergents (washing powder
could have been included).
1 http://ec.europa.eu/environment/eussd/smgp/pdf/JRC_DRAFT_EFLCIA_resources_water_landuse.pdf
2 ILCD Handbook: Framework and requirements for LCIA models and indicators” EUR 24586 EN – 2010).
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It was hard to address this topic during the pilot phase, because the selected pilots could not be
easily enlarged during the pilot phase. The EC however addressed this topic for PEFCRs with a too
broad scope. The concept of subcategories was added to the PEF Guidance document. “When within a
product category several different applications are supported, several RPs may need to be identified.“
(PEF Guidance 6.0, section 2.1). In line with these requirements, the batteries pilot introduced five
product subcategories to take different battery applications into account, so batteries in cars cannot
be compared to batteries in laptops for example. Another nice example to manage the scope of a
PEFCR is the thermal insulation pilot. This pilot managed well to find a balance between keeping a
broad scope to avoid that the PEFCR would have limited applicability, as well as making specific rules
for specific applications. In order to do so, the thermal insulation pilot developed a PEFCR including
horizontal rules (overarching) and vertical rules (application specific). The horizontal rules provide the
framework in which future vertical rules could be developed. The approach resulted in a well-
structured and consistent PEFCR.
It is the question if the functional unit alone is sufficient for determining the scope of the PEFCR. After
all, the functional unit can be defined at a high level, but also at a detailed level, leading to different
scopes. The PV electricity pilot for example has formulated its functional unit as follows: “as 1 kWh
(kilowatt hour) of DC electricity generated by a photovoltaic module”. This supports fair comparisons
of PV electricity, but it does not allow for the comparison of gas-fired electricity or wind power
generated electricity with PV electricity, while this may be very worthwhile when one wants to
support the use of electricity with a low environmental footprint. Therefore, additional criteria could
help companies to choose a meaningful scope for their PEFCR. An additional criterion could be: define
the PEFCR scope based on the functional unit, choosing the functional unit at such a level that all
competing technologies sold at the European market that fulfil the same functional unit are included.
The EC is currently investigating this.
Normalisation for toxicity: As described under criterion 2A, the impact assessment method for
toxicity, USEtox, was criticized by pilot testers. In addition, normalisation factors of the three toxicity
impacts (human toxicity cancer effects, human toxicity non-cancer effects, and freshwater
ecotoxicity) do not reflect the actual European situation, due to data limitations on toxic releases in
national statistics (especially metals). Moreover, it is the question if a global reference situation is
preferable over a European reference situation, because supply chains often originate in countries
outside Europe. The Joint Research Centre is currently updating the normalisation factors of various
impact assessment methods, and develops normalisation factors using the global reference situation.
The normalisation of results is only an issue when products are compared based on normalised
results.
Weighting sets: During the pilot phase, the weighting for each impact category was equal. This
working procedure helped to park the weighting issue and to move forward with the pilot phase.
Weighting has been discussed during the pilot phase, among others in an expert workshop in
November 2015. Pilots were also allowed to test various existing weighting sets during the pilot
phase. Currently, JRC works on developing a weighting set (expected to be published in April 2017).
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Weighting sets inherently involve value choices. It is therefore possible that product comparisons
based on normalised and weighted results may be more intensely discussed by stakeholders.
Use stage and end-of-life conditions: The use stage and end-of-life of products should reflect the
environmental performance of products rather than differences in national conditions, e.g. national
electricity mix. Currently, the use stage and end-of-life stage are modelled in such a way that
country-specific conditions are taken into account. Ensuring fair product comparison would mean
considering the same use and end-of-life conditions for products sold in the same commercial
market. This can be done either at macro level by considering an average European situation for all
products (use stage and end of life) or at micro-level considering country specific situations, which
would require to duplicate the benchmark and make them country-specific.
Data needs matrix: The data needs matrix largely increases the harmonisation of used data among
products which enhances product comparability (see also criterion 2A).
2C. PEFCR/OEFSR enables product/organisation improvements from an environmental
point of view
This criterion relates to the flexibility in the PEF/OEF method. Flexibility in the method allows
practitioners to differentiate the environmental performance of products. This flexibility should not be
on the expense of the comparability of PEF profiles however (see 2B).
Data needs matrix: The data needs matrix (DNM) plays an important role in the way in which
companies shall calculate their PEF/OEF profile result. The DNM provides strict requirements which
enhance harmonisation in PEF/OEF profile results. On the other hand, the DNM creates flexibility
because a company itself determines to a large degree if they have access to company-specific data
when the activity is not run by the company. This allows companies to show the environmental
performance of company-specific processes and allows differentiating their product against those of
competitors.
Every PEFCR includes a list of mandatory processes for which primary data shall be collected. In
addition to this, a company can differentiate the environmental performance of its product by using
company-specific data instead of default secondary datasets for the remaining processes in situation
1/other processes, and in situation 2 in the Data Needs Matrix. This also gives the company the
possibility to choose the data that will result in the best environmental performance. Verification shall
play an important role here.
For many products, it is not easy to access company-specific data for processes far upstream or
downstream the product life cycle, because there is often no direct contact with these companies or
consumers. This largely determines on which basis products are compared. When the impact is the
highest in upstream or downstream processes, secondary datasets are used, and the products are
compared on differences in a few processes, e.g. the energy efficiency in the production plant of the
company carrying out the PEF study. This issue is relevant for pilots where the impact is the highest
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in upstream or downstream processes, e.g. detergents and coffee pilot. This was one of the reasons
for the Commission to introduce benchmark results excluding the use stage.
Success indicator 3: Simplification compared to conventional LCA
Summary of findings
The main aspects that contribute to the success indicator of simplification compared to conventional
LCA are presented below together with the benefit they bring.
Table 2. Overview of main aspects contributing to simplification compared to conventional LCA and
resulting benefits.
Aspects Benefits
Existence of PEFCRs and OEFSRs compared to
conventional LCA or PCRs
Less expertise needed to conduct a PEF/OEF study
Materiality principle It simplifies PEF and OEF studies because data
collection is focused on hotspots, not on
unimportant processes
Background data and models available for use in
PEF and OEF studies
Only collection of foreground and activity data is
needed
Harmonization It avoids confusion and debate It avoids confusion
and debate and thus lower costs of conducting the
PEF and OEF study.
Detailed findings per criterion
3A. Existence of PEFCR/OEFSR simplifies compared to conventional LCA or PCRs
PEFCRs and OEFSRs are documents that determine how PEF and OEF studies need to be carried out
per product category or organizational sector. The PEF/OEF Guide and related PEFCRs/OEFSRs
provide much more specific guidance than the generic LCA guidance found in handbooks or general
standards. This leads to specific rules and many of the methodological and modelling choices have
been made in advance in these documents. For instance, a PEF study that will be executed on basis
of a PEFCR no longer needs to determine the functional unit or the allocation rules to be applied or
the default activity data and background datasets to be used because these have been defined in the
PEFCR. We also expect that less sensitivity analyses are needed because many of the methodological
choices have already been made. These pre-defined choices will make the process of conducting a
PEF or OEF study much simpler than if PEFCRs or OEFSRs didn’t exist. Also, this is likely to reduce the
effort and complexity of the review of PEF and OEF studies.
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Specific product category rules (PCRs) exist managed by different program operators (e.g.
Environdec) and for specific programs (like environmental product declarations, etc). That often
results in many PCRs for the same products available on the market. Although product category rules
(PCRs) have a similar objective to that of PEFCRs, they don’t reach the same result. The rules defined
in PCRs are often still too general, e.g. end-of-life allocation rules are not provided. The PEFCRs are
also unique in the very rigorous definition of the data quality requirements and the required
documentation and transparency of the data. Also, a unique aspect is that the PEFCR is not just a
document with guidance but is accompanied by a list of datasets to be used for secondary data (see
criterion 3C below). Finally, there is a big difference in the stakeholder involvement and the
acceptance: any party seems to be able to develop a PCR whereas a PEFCR can only be developed if
at least 50% of the market share of that product category is represented by those developing it. This
increases significantly its credibility.
Although the development of PEFCRs/OEFSRs will significantly reduce the efforts in carrying out PEF
and OEF studies, the development of a PEFCR/OEFSR is quite technical and labour-intensive. Of
course, this was particularly the case during the pilot phase because it was all work under
construction. We believe that developing future PEFCRs and OEFSRs post pilot phase will be quicker
and smoother but this is still a step that demands significant effort by all parties involved.
The main benefit resulting from the existence of PEFCRs and OEFSRs is that less experience and
expertise is needed to conduct PEF and OEF studies for which PEFCRs and OEFSRs exist. Limited
expertise can be partly solved with detailed guidance provided in PEFCRs and OEFSRs. For instance,
an applicant of a PEFCR does not need to know all possible end-of-life allocation rules nor to test
them all because one single formula for use is clearly specified in the PEFCR/OEFSR.
3B. Materiality principle
In conventional LCA studies a distinction is made between foreground and background systems,
which also determines what data to be collected, namely primary data for the first and secondary
data for the latter. In the Environmental Footprint initiative, two aspects have to be considered: 1)
materiality (i.e. focusing where it really matters, meaning that the data collection is to be focused on
the processes that contribute the most to the environmental performance of the product) and 2) the
level of influence (does the company applying the PEFCR run or have access to primary data for a
process?). With this approach, a company applying a PEFCR only needs to collect primary data for
mandatory company-specific data (this is determined in each PEFCR), and for data that they can
access and has a large contribution to the environmental performance (i.e. most relevant processes).
This provides, on the one side, a lot of clarity in what data is expected to be collected by the
company, and on the other side, a reduction of efforts to collect data compared to conventional LCA.
We also believe that this will lead to overall higher quality data being used in the PEF study and,
consequently, substantiating any claims made from it.
When it comes to the simplification success indicator, a downside of the data requirements in the
Environmental Footprint initiative is the need to (re)calculate the data quality score of many
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processes. While it sure makes sense to include this as a guarantee of a PEF study made with high
quality data, this requires extra effort in comparison to conventional LCA.
The main benefit derived from the materiality principle is that PEF and OEF studies can focus on
hotspots instead of spending a lot of time on less important processes as is often the case in
traditional LCA.
3C. Background data and models available for use in PEF and OEF studies
The availability of quality checked secondary data is a great simplification. In conventional LCA, any
LCA practitioner has to decide what secondary data to be used and from which source. Neither high
quality data can be guaranteed nor the consistency within and accessibility to these data. The EC is
currently purchasing EF-compliant datasets with a minimum data quality score and these will be
freely available to companies that will apply the PEFCRs and OEFSRs approved during the pilot phase.
These datasets will also be listed as the default secondary datasets to be used for all PEFCRs and
OEFSRs so a company applying these rules will know exactly what secondary dataset to use and
where to implement it in the model.
Another novelty in the EF pilot phase that leads to simplification is the access to the models of
representative products (RPs) and representative organizations (ROs). At the end of the pilot phase,
the Commission will make available the models of all RPs and ROs so that companies that apply
PEFCRs and OEFSRs also have a model to start with. This way, they don’t need to model from scratch
and, even if they do, for instance, if the software tool they will use is not able to make the models
available, the practitioner can re-build the model very easily using the model made available in Excel.
Availability of default secondary data and models is also likely to ease making a product portfolio
analysis within a company. For instance, from one product to another of the same product category
manufactured by the same company only specific activity data values for each need to be filled in,
e.g. the bill of materials and the mass of different materials going to end of life.
Availability of background data and models for use in PEF and OEF studies bring great benefits. Now,
only collection of foreground and activity data is needed and differences in results obtained for
different products can be attributed to differences in foreground and not in background data.
3D. Harmonization
Every company is looking for credible and robust sustainability metrics to use. So, a consensus
approach like the one resulting from the EF pilot phase avoids confusion and debate inside companies
and among other stakeholders (once it’s finalised, there was a lot of discussion within the pilot phase
and the development of the documents). Taking an existing consensual approach saves a lot of time
in the decision-making process at companies. It is also very important that many of the TS are being
coordinated by European branch associations because this reinforces the endorsement for the whole
industry at European level. This strengthens the applicability of the PEFCRs and OEFSRs in the future
by all member companies of the associations. All in all, we expect that it will be much easier to
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support an internal decision on a short notice as all is standardised, and that it will be faster to make
an external claim.
A harmonised and well-accepted methodology will be of great benefit to companies, the target
audience of the PEF results and to the LCA community at large as we believe that those parties will
stop debating the methodology and, instead, start competing on the results. Hopefully, this
transparency in the results will also lead to healthy competition towards better environmental
performance and, consequently, that each company starts improving their value chain with
sustainability in mind.
Success indicator 4: Reduced costs for companies for the environmental analysis
Summary of findings
This section assesses costs reduction for companies once the pilots phase will be finalized. This
analysis considers thus the foreseen October 2017 situation and not the situation at the time of
writing this report.
Reduction of costs mostly refers to time savings to perform a PEF/OEF study, and hence this section
has strong links with success indicator 3. Figure 1 gives a quick overview of the time savings for
conducting a PEF/OEF study depending on the guidance available for a sector. PEFCR/OEFSR, RP/RO
models and SME tools reduce the effort for performing environmental analyses by providing guidance
on goal and scope, data collection and life cycle impact assessment and providing default data.
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Figure 1. Reduced costs for companies for conducting a PEF/OEF study
Detailed findings per criterion
4A. Reduced resources for a sector working together to develop a PEFCR/OEFSR
Developing a PEFCR/OEFSR is a time-consuming process which is done beforehand in order to save
time later on, when carrying out PEF/OEF studies. Wide involvement of companies, producing
products in the same product category, is required during the pilot phase to develop a PEFCR. The
Technical Secretariat must be representative of at least 51% yearly turnover. This means that many
companies, and thus possibly different interests, sit together. This rule has two opposite
consequences when considering financial aspects:
PEFCR/OEFSR development costs are supported by a large panel of companies, which limits the
cost per stakeholder.
Political discussions regarding strategic orientation within a technical secretariat may be time
consuming and delay the process.
Note that the technical secretariats involved in the pilot phase have faced many additional costs due
to the changing rules and expectations along the pilot phase. As the rules have now been defined,
the average time required to develop new PEFCR/OEFSR should be significantly lower than the time
spent on the development of the PEFCR/OEFSR within the pilot phase.
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4B. Reduced resources for companies when a PEFCR/OEFSR is available
As a guidance document, a PEFCR saves practitioners time by giving a well-defined framework, as
detailed in criterion 3A. In practice, three steps of a PEF study are especially affected:
Goal and scope definition: PEFCRs define the key elements from the goal and scope chapter from
usual LCA studies: functional unit, system boundaries, Life Cycle Impact Assessment (LCIA)
methodology, types and source of data, data quality requirements, and allocation rules.
RP/RO modelling: PEFCRs/OEFSRs will reduce time required at modelling stage by providing clear
guidance. Beyond this guidance, the availability of RP/RO models allows practitioner to already
have a model in the right format or to build it based on Excel models (see criterion 4D).
Life cycle impact assessment: PEFCRs have defined the most relevant indicators. This allows the
practitioner to save time by not analysing the non-relevant ones.
On the other hand, the strict requirements regarding calculation of DQR will increase significantly the
workload to perform a PEF study. Indeed, 3 of the 4 parameters from the DQR formula are context
specific, i.e. they have to be reassessed within the context of the specific PEF study. The DQR must
then be calculated for all the processes contributing to at least 80% of the single score impact.
4C. PEFCR/OEFSR includes secondary data for all processes
The list of background datasets to be used and their availability free of charge will allow two gains:
Time savings when building a PEF/OEF model, as detailed in criterion 3C.
Savings due to background dataset availability free of charge: Companies performing PEF studies
may save money due to the availability of background datasets free of charge. It is indeed
possible to perform a PEF/OEF study without any software or database license cost.
4D. SME tools available
SME tools will be available for a limited number of PEFCR (15%): beer, leather, olive oil, and t-shirt.
These tools will be accessible to non-experts, and will be simple and attractive. The software will be
open source, so that other pilots can reuse the code to build their own tools. The SME tool aims at
covering 90% of all software requirements for any PEFCR/OEFSR and to have a mechanism that
allows adaptations for particular PEFCR/OEFSR (plug-ins development).
In case such SME tool is available, the following costs savings are expected:
Time savings due to the availability of RP model ready to use with a user-friendly interface. No
time spent to model and integrate background datasets.
Financial savings as it is not needed to purchase any LCA software license nor commercial
database
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As the SME tools are not available at the time of writing this report, the specific features are not all
known yet. For example, DQR calculation might be part of the SME tool, which would also save time.
This means that the remaining work to complete a PEF study of a specific product refers mostly to
primary data collection and analysis of the results. Note that even if getting quick results will be very
easy, making it a PEF-compliant study will still need a minimum of LCA expertise.
4E. RPs and ROs models are available
RPs and ROs models will be made available for all the PEFCRs/OEFSRs developed within the pilot
phase by the Commission at the end of the remodelling process. These models will help reducing
costs of PEF/OEF studies, whoever carry out the study for the following reasons:
Lower expertise required to get PEF/OEF results, as detailed in criterion 3A.
Time savings due to the avoided modelling step, as detailed in criterion 3C.
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Annex 1. List of technical issues
The list below shows the technical issues that were addressed in the TAB meetings in the period
November 2013 – December 2016.
1. Representative product/organisation
2. Data Needs Matrix
3. Development of level 1 datasets by companies
4. Data quality assessment
5. Circular footprint formula
6. Agriculture modules
7. Green electricity
8. Biogenic carbon modelling
9. Use stage
10. Biodiversity
11. Impact assessment methods
12. Normalisation and weighting methods
13. Hotspot analysis
14. Benchmark calculations
15. Screening
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