The Product Environmental Footprint: the retail and wholesale perspective

The European Green Deal and, under it, the new Circular Economy Action Plan have created an even stronger focus on sustainability and environmental labelling in EU policy. The Commission’s Product Environmental Footprint (PEF) method aims to give consumers verified information about the impact on the environment of what they buy.

The COVID pandemic has made consumers even more interested in the sustainability of (food) products and especially in relation to their health. The retail and wholesale sector communicates with millions of customers every day through product labels, leaflets, websites and other modern means of communication. Regulation has added considerably to the information required for food and non-food products; to respond to consumers’ wishes, manufacturers and our sector have added further voluntary information on products. While being mindful of the need to avoid consumers suffering from information and labelling overload, we support the Commission’s goal of better addressing greenwashing with the upcoming proposal on substantiating green claims, which will feature the PEF method. False claims harm everyone, and as a common minimum, consumers need a scientifically-grounded methodology and reliable information.

On the ground, manufacturers, retailers and even academic and public bodies are looking to be frontrunners and have started to explore ways how to use PEF as the basis for environmental labelling and communication with consumers. At the same time, we also hear from other market players who are less convinced that PEF can be used for such an ambitious goal and also let consumers easily understand the information they are provided with. In this, we need to take account of the situation of SMEs, who often lack the resources and expertise to conduct footprint studies for their products.

Our members have experience with PEF and have followed and participated in PEF pilots since 2013. While PEF could be useful as a voluntary communication tool in B2B relationships and supply chain cooperation, it is not suited for B2C communication.  An EU label based on PEF or a legal obligation to communicate with consumers only via PEF methods is therefore not our preferred way forward. We would suggest that in parallel to the work undertaken with PEF, the Commission could support efforts for more harmonisation, for example through common guidelines or official recognition of top-performing schemes and standards like the ISO 14024 Type 1 ecolabels.

As an alternative the Commission should perhaps focus on further promotion of the method and give companies free and public access to data, databases, guidelines and calculation tools. This would help our sector, as well as businesses in other supply chains, and specifically SMEs. We believe that continuing work done in the pilots and the Environmental Footprint Transition phase could help voluntary development of new PEF category rules.

This approach would allow exploratory projects based on PEF to continue, without committing now to one way forward to the exclusion of others. It will be key to look at further developing and updating the PEF methodology, irrespective of the content and scope of the Commission’s legislative proposal on green claims. We will be looking to work with our partners in the supply chain and with decision-makers to make the most out of PEF and find uses that really help consumers to recognise sustainable products when choosing what to buy.