PEF vs EPD: aligning now saves rework later

5 min read
Published: September 9, 2025

European buyers will soon ask for Product Environmental Footprint (PEF) numbers alongside or even instead of traditional EN 15804 EPDs. The two frameworks share DNA but differ on impact categories, modelling choices, and data granularity. Manufacturers that map the gaps today avoid duplicate LCAs tomorrow and stay ready for looming EU green-claims rules.

Image of Product Environmental Footprint (PEF) and PEFCR alignment article

PEF in plain English

Think of a Product Environmental Footprint as an LCA with extra guard-rails from Brussels. The European Commission baked 16 midpoint impact categories into one mandatory recipe and updates the characterisation factors centrally (European Commission, 2025). The goal is apple-to-apple comparability across every shampoo bottle, steel beam, or sneaker sold in the EU.

Meet the PEFCRs

PEF Category Rules (PEFCRs) do for PEF what PCRs do for EPDs: they lock down functional units, data quality, and allocation rules for a product group. The first final PEFCRs—apparel and footwear—landed in June 2025 and already feed the Digital Product Passport pilots (European Commission, 2025). More sectors are queued for 2026-2027.

How close is EN 15804 now?

The 2019 A2 amendment pulled EN 15804 toward PEF by adopting the same 16 impact indicators, but major rifts remain on normalisation, weighting, and end-of-life modelling (Nordic Council, 2024). A 2024 comparison study warns that results are still not interchangeable for decision-making (Resources, Conservation & Recycling, 2024).

Why alignment matters for revenue

EU public tenders worth roughly €2 trillion a year can soon cite PEF results as proof points. Early movers will face fewer clarification rounds, win specification slots faster, and sidestep expensive LCA redraws when clients escalate from EPD to PEF.

Data headaches you can anticipate

  • Datasets must reference EF 3.1 nomenclature.
  • Energy and transport mixes mirror EU averages unless primary data prove otherwise.
  • Cut-off rules tighten to 1 % of mass and environmental relevance, shrinking the wiggle room common in legacy PCRs.

Plan extra time for foreground data hunting—especially Scope 3 process flows your current EPD may treat as secondary.

Four alignment moves to start this quarter

  1. Compare your latest EPD model to the 16 EF categories; flag missing tox or water metrics.
  2. Map where end-of-life formulas differ; PEF’s circularity credits can flip impact rankings.
  3. Update background databases to the EF-compliant versions of ecoinvent or GaBi.
  4. Draft a crosswalk showing which inventory parameters satisfy both a PEFCR and your existing PCR. That document becomes the brief for whoever crunches the numbers.

Regulatory crystal ball

The Green Claims Directive wobbled in June 2025, but Brussels keeps signalling that any future eco-label checks will lean on PEF methodology. National ecolabels in France and the Netherlands already reference PEF in draft updates. Betting against alignment looks risky.

The takeaway

If Europe is on your sales roadmap, treat PEF compatibility as a design input, not an after-thought. Build datasets once, export them to both EPD and PEFCR formats, and you will shave months off every future credential request while competitors start from scratch.

Frequently Asked Questions

Will my existing EN 15804 EPD automatically count as a PEF study?

No. Despite sharing the same 16 impact indicators since the 2019 A2 revision, PEF demands stricter data quality, fixed characterisation factors, and different end-of-life credits, so results are not directly transferable.

Can I publish one document that satisfies both PEF and EPD requirements?

Yes in theory, but only if you model data once to the stricter PEF rules, then format outputs separately for your EPD program operator.

How long does a PEF study take compared to an EPD?

Timelines are similar if your datasets are complete. The bottleneck is usually gathering primary supplier data at the granularity PEFCRs require.

What happens if the Green Claims Directive is dropped?

Even without that law, EU product-specific regulations (ESPR, sectoral ecolabels) point to PEF as the benchmark methodology, so the business case for alignment stands.