In 2013, the European Commission started to develop a methodology for Product Environmental Footprint (PEF) to be eventually used in upcoming policies and legislation on product-related issues as a vital component in its 2020 programme for a “Single Market for Green Products”. The PEF work is based on a number of ISO standards for LCA and EPD. A large part of the work has focused on developing “Product Environmental Footprint Category Rules, PEFCR”, for some 25 different product categories. These pilot studies are now completed and the PEF work has entered a transition phase where all results and experiences gained so far are being evaluated. The developments of PEF have been followed with great interest, also in other countries outside Europe as a possibility to facilitate the comprehensiveness of environmental information of products, especially to end-consumers.
The Commission recently launched a public survey to gather information from industry, practitioners, public administrations and other stakeholders as a part of the transition phase of the PEF methodology. As an umbrella organization for EPD Program Operators and a platform for all other relevant stakeholders like European Trade Associations, Green Building Counicls or Rating Scheme Operators as well as LCA experts, ECO Platform has sent their input to improve the application of PEF in Europe, focused in the main expertise of our organization, and a reliable verification of LCA-data based on the existing EPD method.
The position of ECO Platform is that for construction products the European Standard EN 15804 should be the basis for any LCA, as a consensus achieved methodology with industry and other stakeholders in the European Committee for Standardization (CEN). The EPD, considered as a neutral dataset, should be used when applying any scenarios or benchmarks. This offers flexible use-scenarios of the EPD datasets for various use-types, avoiding multiple efforts for industry. Next to using the EPD data for PEF, it could be, for example, used for Building-LCA Tools in Green Building Rating Shemes or in BIM as well as input data for any eco-labelling or individual scenarios with own benchmarks for public and private procurement.
In regard to verification, the current structure of EPD Programme Operators managing the procedures, the qualification of verifiers, the development for the PCR and other tasks association with the assessment of conformity has proven to be sound and solid, with thousands of verified EPD in Europe according to EN 15804. The verification procedures for environmental footprints should consider the experience from industry and EPD Programme Operators in the development of rules and criteria for the verification of the PEF results.
ECO Platform is willing to cooperate with the Commission in the development of a communication system ensuring the provision of reliable environmental information for products in the fields of construction products, as well as electric, electronic and HVAC-R.
The full reply from ECO Platform to the survey and our position paper can be found here:
Letter PEF-Survey ECO-Platform
Our Response
