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White Paper exposes flaws in EU’s Product Environmental Footprint system

A recently released white paper by Make the Label Count coalition has cast a spotlight on significant shortcomings within the EU’s Product Environmental Footprint (PEF) system, raising concerns about its effectiveness in advancing the EU's environmental goals.

Jangoulun Singsit July 07 2026

The document, which scrutinises the Product Environmental Footprint (PEF)'s current framework, argues that the system is ill-equipped to support the EU's Green Deal and Circular Economy Action Plan (CEAP) due to its inadequate assessment of sustainability, particularly in the context of synthetic fibres and fast fashion.

The PEF system, developed by the European Commission, is intended to standardise the evaluation and communication of products' environmental impacts across the EU market.

However, the white paper highlights that the system's reliance on 16 indicators fails to capture the full spectrum of environmental impacts, particularly those associated with synthetic materials.

This gap in the methodology could potentially mislead consumers and hinder the EU's environmental policy objectives.

One of the primary criticisms outlined in the white paper is the PEF's exclusion of critical indicators such as microplastic emissions, plastic waste generation and direct circularity matrix.

According to the paper, these omissions are particularly concerning given the environmental challenges posed by synthetic fibres, which are largely derived from non-renewable fossil feedstocks.

The white paper advocates for the inclusion of additional indicators, such as a circularity indicator, to enhance the PEF's alignment with sustainability principles. By doing so, the system could facilitate more equitable comparisons between products from extractive and non-extractive industries, thereby promoting a transition to a circular economy.

The paper states the solutions will be most effective when they are accompanied by PEF single score weighting factors that reflect their importance to informing and advancing the EU environmental policy.

Despite its potential, the PEF system, as it stands, is not positioned to effectively deliver on the EU's environmental policies.

The coalition warns that without addressing these methodological flaws, the PEF system may inadvertently support unsustainable consumption patterns and undermine the EU's efforts towards a sustainable transition.

"By adopting the recommendations, there is potential for the PEF system to (1) provide more meaningful guidance to EU consumer purchasing decisions and to (2) assist in delivery of the sustainability objectives of EU environmental policy through fair comparisons of natural and synthetic fibre textiles in PEF," reads the white paper.

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