European Commission Actions: Proposing Environmental Footprints for Products and Organizations

    View Author 22 May 2014

    The European Commission is piloting environmental footprints for products and organizations to include carbon and other environmental measures, for products sold in the European Union or internationally. The next tranche of products to be piloted for environmental footprinting will begin June 1, 2014.


    The European Commission (EC) is developing a methodology to calculate the environmental footprint of products and organizations known as “Product Environment Footprints (PEFs)” and “Organisation Environmental Footprints (OEFs).” PEF and OEF forms and compliance could be required for a variety of products that are sold in the European Union (EU), or traded internationally by EU member countries. The EC is recommending the use of environmental footprint methodologies to Member States, companies, private organizations and the financial community and is currently undertaking “a testing period to develop product- and sector-specific rules.” The next tranche of products to be piloted for environmental footprinting will begin June 1, 2014. Patton Boggs can assist with facilitating stakeholder participation in the process.

    By way of background, EC member states have been the driving force behind the development of Product Environment Footprints and Organisation Environmental Footprints since 2008. That year, the Council of the European Union recommended in its conclusions to the report, “Sustainable Consumption and Production and Sustainable Industrial Policy Action Plan” that the EC “start working as soon as possible on common voluntary methodologies facilitating the future establishment of carbon audits for organisations and the calculation of the carbon footprint of products.”  Since that time, the EC has undertaken an effort to take into account greenhouse gas emissions (GHG) as well as a “broader suite of relevant environmental performance criteria” in developing environmental footprints for products and organizations. The final Product Environmental Footprint and Organisation Environmental Footprint methods were issued in April, 2013.

    The EC initially tested several sectors for PEF viability including: agriculture, retail, construction, chemicals, information and communication technologies (ICT), food, manufacturing (footwear, televisions, paper). The EC’s first wave of actual products piloted for PEFs included: batteries and accumulators; hot and cold water supply pipes; IT equipment; metal sheets; photovoltaic electricity generation and uninterruptible power supply, among others. The comment period on those pilots closed April 30, 2014. The second wave of testing for pilot PEFs will begin on June 1, 2014 for the following products: beer, coffee, dairy, feed for food-producing animals, fish, meat (bovine, pigs, sheep), olive oil, packaged water, pasta, pet food (cats and dogs) and wine. The EC encourages participation in shaping the Product Category Rules (PCR) for the selected pilots and has issued the following caution against remaining silent in the process by noting that:

    The PEFCRs resulting from the EF [Environmental Footprint] pilot phase will become the product rules valid under the PEF, to be used by all stakeholders in the sector in the EU or internationally who decide to measure the performance of their products based on PEF.

    The EC is also working on developing health product declarations, which would be similar to PEFs, and are intended to describe product content and direct health hazards associated with exposure to the product’s individual contents. 

    Patton Boggs stands ready to assist companies that may want to participate in the development of the Product Category Rules in the environmental footprinting process for products and organizations and/or the development of health product declarations as the European Commission moves forward in these areas.