Our first impressions

The methodology used in life cycle assessments (LCA) is a general framework that leaves a lot of room for adaptation and interpretation. It was originally meant for academic research, but in recent years, the use of LCA tools has become increasingly consumer-facing. In response to this shift, the EU felt compelled to regulate the way that products are calculated, including the introduction of detailed adaptations for individual categories. 

Unlike the methodology described in ISO14040, the PEF features specific rules for different product categories. This includes setting clear guidelines about what has to be calculated, databases that can be used for data completion and allocation purposes, as well as how to present and report on the research. 

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This new framework will take into account all supply chain activities, from the extraction of raw materials, to the production and use phase, through to the waste management of a product. This regulation is a significant step in the evolution of LCA tools, as well as the way results are communicated, so whether you agree or disagree with the regulations, they will be impossible to ignore. 

It is important to note that the final specifications have not been published yet, but from our initial inspection, one of the key points to notice is that each item will have to go through a third party approval. 

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Our concerns

Here at Made2Flow, we have some concerns about the incoming regulation. 

1. Data. The PEF regulators have made the decision to regulate the database and allocation work, which is a tremendous task that could, in theory, be very beneficial in aligning all statements. However, considering the current state of the industry, where more data is missing than it is available, we believe this decision is questionable. Additionally, the industry data that’s currently available is often unvalidated, so if the incoming regulations are based on incorrect information, this will lead to misinformed decision making. The risk is that this could lead to more greenwashing – not less. 
2. Use phase. It is only possible to validate data through the supply chain after putting in a lot of hard work on traceability and data gathering. In contrast, when it comes to the use phase of a product, brands will be forced to apply assumptions or unify calculations for garments of different use, need, or occasion of use. This could create inaccuracies in data, defeating the purpose of category-specific guidelines. 
3. Implementation. The industry will comply, but mostly through key products or Never Out Of Stock items, as the PEF regulations will require verification by a third party for each item declared, resulting in delays and augmented costs. This represents only part of a brand’s offering. In conjunction, brands will measure the entirety of their collections to guide decision making and organizational scope. By doing so, brands will be able to fully understand where the impact is, and how to reduce it, in line with science based targets. 

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What to look for in an environmental impact provider 

To ensure you’re working within the guidelines of the PEFCR, and to avoid potential scrutiny, here’s what to look for when choosing an LCA partner. 

1. The ability to incorporate and use multiple databases for more accurate measurements. 
2. Ensure that existing data from tiers 1- 4 is collected globally. 
3. The ability to validate the data collected. 
4. The ability to provide complete data transparency, including data sources for each item.