To PEF or not to PEF? Make all green claims robust

In early 2023, the European Commission will present an initiative to put green claims in check. Most likely, green claims made on products will have to follow the PEF - Product Environmental Footprint - calculation method.

Claims companies make on the environmental performance of their products and activities are increasing. Sustainable products and processes, sustainable investments, green bonds, carbon neutral packaging…. Showcasing environmental footprints has become a marketing strategy, regardless of how reliable or relevant the information is.

There is a great need to regulate these claims. Legislation needs to be clear about what can or cannot be claimed. Today, environmental information available to consumers is often self-awarded by manufacturers, and ranges from robust claims backed up by legislation to a variety of unsubstantiated, vague, irrelevant, misleading, or even factually wrong information.

Environmental transparency and the fight against greenwashing need to become a global policy priority – only this way will it serve its noble purpose of empowering sustainable choices.

The tide is turning in the European Union

Luckily, in early 2023, the European Commission will release a proposal for a regulation on substantiating environmental claims. The initiative was previously foreseen for release in November 2022. Complementing the March proposal for the Empowering Consumers in the Green Transition Directive, which deals with generic claims and misleading practices, the EU is now looking into how specific environmental claims, such as ‘50% less CO2 emissions’, should be communicated.

This is a commendable initiative in itself – as long as it does not miss the mark and truly helps fight greenwashing.

Which way to go?

Two scenarios are on the table. The Commission could oblige companies to use the Product Environmental Footprint (PEF) method to substantiate claims. However, the PEF methodology covers only a narrow list of impacts. This would leave many green claims on other important impacts, such as the share of recycled content, unregulated.

Alternatively, the initiative could cover green claims beyond aspects in the scope of the Product Environmental Footprint. This would include reusability, recycled-content, or recyclability. Doing so, the Commission would ensure that all companies understand, assess, communicate and justify green claims in a comparable and consistent way – and could finally put an end to the Wild West of green claims.

The limitations of a PEF-only scenario

PEF is the European method to measure the environmental impacts of products throughout their whole lifetime. It covers 16 categories of impacts: climate change, ozone depletion, human toxicity (cancer and noncancer), particulate matter, ionising radiation (human health), photochemical ozone formation (human health), acidification, eutrophication (terrestrial, freshwater and marine), ecotoxicity (fresh water), land use, water use, resource use (minerals and metals) and resource use (fossils).

The upcoming Commission initiative intends to primarily look at green claims presenting one of these environmental impacts, such as the carbon or water footprint of products.

For green claims made on one single impact covered under the PEF scope, the initiative would definitely bring more transparency and more clarity to the market. However, such a PEF-focused initiative would have two main shortcomings.

First, it could encourage companies to communicate the results of a fully fledged PEF assessment (covering all 16 impact categories) in a way which could be misleading. Communication to consumers is often based on simple aggregated scores (such as the French Nutriscore) but when it comes to PEF, there is currently no plan to ensure that aggregating the 16 impact categories will not lead to hiding negative impacts. For example, a good score in climate change should not mitigate a low score in human health.

Secondly, many key environmental impacts which are often communicated as green claims on products are not covered under PEF. This includes biodegradability, recyclability, durability, reusability, reparability, or microplastics release. Many of these aspects are recurringly used in communications made by manufacturers – and, should the PEF scenario become real, will remain unregulated. In other words, restraining the scope of the initiative will fall short of providing a satisfactory answer to widespread greenwashing.

What should the Commission do to fix this?

First, it is extremely important to widen the scope of the initiative beyond impacts covered by PEF. It is not because certain aspects are not covered under PEF that they are less relevant to be regulated or should be left out. The fix is rather easy: there are robust methodologies out there laying down the conditions under which important impacts, such as product durability, should be claimed.

In our 2021 report ‘Too good to be true? A study of green claims on plastic products’, we provide recommendations on how to best communicate on a number of environmental aspects, including recyclability, reusability or recycled content.

Building on the UNEP Fundamental Principles for providing product sustainability information, ECOS wants to see policymakers and standardisers eliminate loose definitions, ensure that the circular hierarchy is respected, assess characteristics based on real-life conditions using robust accounting and verification methods, and ensure evaluation and transparency of claims.

Companies wishing to boast about the environmental performance of products must do so by providing the consumer with full and frank information. Only this way will brands build consumer trust, enable fair comparison with competitors, and genuinely help protect the environment – something the European Commission should definitely seek to achieve.