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Evaluation report Technical evaluation of the EU EF

pilot phase

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Evaluation report Technical evaluation of the EU EF pilot phase

By: Annemarie Kerkhof and Wouter Terlouw (Ecofys)

Marisa Vieira (PRé Consultants)

Céline Alexandre and Remi Bagard (RDC Environment)

Date: April 2017

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Executive summary

Introduction

This evaluation report focuses on the technical content developed during the Environmental Footprint

(EF) pilot phase and takes the perspective of the Technical Helpdesk. During the EF pilot phase,

various sectors developed Product Environmental Footprint Category Rules (PEFCRs) or Organisation

Environmental Footprint Sector Rules (OEFSRs). The evaluation is based on the experience that the

Technical Helpdesk obtained in supporting the pilots and the European Commission (EC) during the

past three years (2013-2016).

The Technical Helpdesk has evaluated the progress and results of the EF pilot phase several times in

the past three years, and shared the findings with the EC during interim and final meetings and

reports. In this evaluation report, we evaluate the pilot phase in the period November 2013 –

December 2016, including previous findings when still relevant. The technical evaluation includes the

PEF Guidance 6.0, OEF Guidance 4.0 and some checks of the final draft PEFCR or OEFSR (submitted

to the EC at the latest by 31 January 2017). In the report, we also evaluate the simplification and

cost reduction of the availability of RP/RO models, SME tools and EF-compliant datasets which are

currently not finalised. Outside the scope of this report are the testing of communication vehicles, the

verification system, and the evaluation of the process of the pilot test.

We have developed a set of criteria to evaluate the EF pilot phase from a content perspective,

considering the following success indicators for the pilot phase defined by the EC at the start of the

pilot phase:

1. Number of pilots that manage to deliver a complete PEFCR/OEFSR

2. Demonstrate that the methodology works in any value chain

3. Simplification compared to conventional LCA

4. Reduced costs for companies for the environmental analysis

Evaluation results

Under leadership of the EC, the PEF and OEF methods have been extensively tested by 26 pilots in a

multi-stakeholder context in the past 3 years. During this period, an impressive number of technical

issues has been picked up and discussed with experts in the TAB meeting. Requirements were written

down in issue papers which have been integrated in the PEF Guidance 6.0 and OEF Guidance 4.0. The

consortium expects that such a rapid methodological development and improvement would not have

happened without the pilot phase and leadership of the Environmental Footprint team of the EC.


77% of all pilots submitted their final draft PEFCR/OEFSR to the EC by 31 January 2017. Since the EF

pilot phase is still ongoing, a final assessment of the completeness of the PEFCR/OEFSR was not

possible at the time of writing this report.

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The concept of PEFCRs and OEFSRs largely increases the harmonisation of PEF and OEF profiles, by

introducing the following elements:

Requirements for the Goal & Scope definition like functional unit and system boundaries

Data Needs Matrix

Requirements for modelling of common elements of product life cycles, like electricity and

disposal

Rules for modelling different life cycle stages

Default impact assessment categories and methods

It is expected that the current development of EF-compliant datasets and RP/RO models will further

increase the harmonisation of PEF/OEF profiles.

The increased harmonisation of the PEF/OEF profiles largely contributes to fair product comparisons.

A few methodological issues need further attention and improvement to ensure fair product

comparisons:

The scope of the product category, or subcategory, covered by the PEFCR is highly relevant

for fair product comparisons. The scope of the product category shall be defined by choosing

the functional unit at such a level that all competing products sold at the European market

that fulfil the same functional unit are included. The EC is currently working on a procedural

guideline on how to identify the relevant granularity level of product groups. This guideline

will complement the current requirements in the PEFCR Guidance 6.0.

The impact assessment of toxicity need to be robust enough to support product comparisons

and benchmarking. The impact assessment method USEtox and related characterisation

factors have its weaknesses which need to be addressed. The Joint Research Centre is

currently working on solutions regarding USEtox, including the development of

characterisation factors with alternative input data, and expanding the list of characterisation

factors in general.

The use and end-of-life stage of products should reflect the environmental performance of

products rather than differences in national conditions such as national electricity mix.

Every PEFCR/OEFSR includes a list of mandatory processes for which primary data shall be collected.

In addition to this, a company can differentiate the environmental performance of its product by

using company-specific data instead of default secondary datasets for the remaining processes in

situation 1/other processes, and in situation 2 in the Data Needs Matrix. This freedom however also

gives the company the possibility to choose the data options that deliver the best environmental

performance. Verification shall therefore play an important role here.

The OEF method was tested by only two pilots which has led to limited experience in using the OEF

method. The issues flagged by PEF pilots during the pilot phase are largely also relevant for the OEF

method. However, some OEF specific topics, like the definition of the representative organisation, did

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not receive special attention during the TAB. The pilot testing led to the insight that comparing

company‘s performance based on OEF studies is not useful.


The PEFCR/OEFSR development process during the pilot phase has been labour-intensive including

various iterations due to methodological improvements. We expect that the PEFCR/OEFSR

development process will take less time post pilot phase because the requirements for the

development of PEFCR/OEFSR will not change, at least not as frequently as during the pilot phase.

However, the development process will still require expertise in Life Cycle Assessment and knowledge

of the specific requirements of the PEF/OEF methods. However, once PEFCR/OEFSR are developed,

the time and expertise needed for creating PEF/OEF profiles is significantly reduced. It is expected

that the final PEFCR/OEFSR, developed during the pilot phase and which will be ready in October

2017, will have a great potential to simplify and reduce costs for conducting PEF/OEF studies,

compared to conventional LCA.

The main aspects that contribute to the success indicator of simplification compared to conventional

LCA are presented in the table below together with the benefit they bring.

Table i Overview of main aspects contributing to simplification compared to conventional LCA and resulting benefits.

Aspects Benefits

Existence of PEFCRs and OEFSRs compared to

conventional LCA or PCRs

Less expertise needed to conduct a PEF/OEF study

Materiality principle It simplifies PEF and OEF studies because data

collection is focused on hotspots, not on

unimportant processes

Background data and models available for use in

PEF and OEF studies

Only collection of foreground and activity data is

needed

Harmonization It avoids confusion and debate and thus lower

costs of conducting the PEF and OEF study.

4. Reduced costs for companies for the environmental analysis

This success indicator can only be evaluated once the final PEFCRs and OEFSRs are available for use

by companies. In this report, we have estimated the cost reduction for companies based on the

expected reduction in resources needed to conduct a PEF/OEF study.

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Reduction of costs mostly refers to time savings to perform a PEF/OEF study, and hence this success

indicator has a strong link with success indicator 3. The figure below gives an overview of the time

savings for conducting a PEF/OEF study depending on the guidance available for a sector.

PEFCR/OEFSR, RP/RO models and SME tools reduce the efforts for performing a PEF/OEF study by

providing guidance on goal and scope, data collection, modelling and life cycle impact assessment

and providing default data.

Figure i Reduced costs for companies for conducting a PEF/OEF study

In summary, the pilot phase has been a joint effort of the EC, pilot companies, involved stakeholders

and supporting parties. The PEF and OEF methods and the related PEFCR and OEFSR approach have

been strengthened in the past three years through the intense testing and immediate implementation

of lessons learnt in the PEFCR and OEFSR guidance documents. However, conclusions can only be

drawn when the EF pilot phase is finalised in October 2017.

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Table of contents

Table of contents 8

List of acronyms 9

1 Introduction 10

Scope of the evaluation 10

Success indicators and criteria evaluated 10

2 Evaluation results 12

Success indicator 1: Number of pilots that manage to deliver a complete PEFCR/OEFSR 12

Success indicator 2: Demonstrate that the methodology works in any value chain 13

Success indicator 3: Simplification compared to conventional LCA 20

Success indicator 4: Reduced costs for companies for the environmental analysis 23

Annex 1. List of technical issues 27

List of acronyms

EC European Commission

CFF Circular Footprint Formula

DNM Data Needs Matrix

DQR Data Quality Rating

EF Environmental Footprint

LCA Life Cycle Assessment

LCI Life Cycle Inventory

LCIA Life Cycle Impact Assessment

OEF Organisation Environmental Footprint

OEFSR Organisation Environmental Footprint Sector Rules

PEF Product Environmental Footprint

PEFCR Product Environmental Footprint Category Rules

RO Representative Organisation

RP Representative Product

SC Steering Committeee

SME Small and Medium Enterprises

TAB Technical Advisory Board

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1 Introduction

This evaluation report focuses on the content developed during the Environmental Footprint (EF) pilot

phase and takes the perspective of the Technical Helpdesk. During the EF pilot phase, various pilots

developed Product Environmental Footprint Category Rules (PEFCRs) or Organisation Environmental

Footprint Sector Rules (OEFSRs). The evaluation is based on the experience that the Technical

Helpdesk obtained in supporting these pilots and the European Commission (EC) during the past

three years. The experience comprises:

Ad-hoc support to pilots

Trainings (face-to-face trainings, webinars, e-learning modules)

Wiki development and maintenance

Technical support to EC (helicopter documents and technical issue papers, for instance on use

phase, biodiversity, electricity modelling, etc.)

Participation in Technical Advisory Board (TAB) meetings

Review of second draft PEFCRs/OEFSRs

Chairing three workshops for the Circular Footprint Formula (CFF)

Scope of the evaluation

The Technical Helpdesk has evaluated the progress and results of the pilot test several times in the

past three years, and shared the findings with the EC during interim and final meetings and reports.

In this evaluation report, we evaluate the pilot test in the period November 2013 – December 2016,

including previous findings when still relevant.

It must be mentioned here that the EC has prolonged the pilot phase to November 2017. The

extended period will mainly be used to remodel the PEFCR/OEFSR models developed by the 24 pilots

using data acquired by the EC, which will result in updated PEFCRs/OEFSRs in October 2017.

Consequently, we were not able to evaluate the pilot phase in its entirety.

The evaluation includes the PEF Guidance 6.0 and some checks of the final draft PEFCR or OEFSR

(submitted to DG Environment at the latest by 31 January 2017). We also evaluate the simplification

and cost reduction that may be realised by the availability of RP/RO models, SME tools and EF-

compliant datasets which are currently not finalised. Outside the scope of this report are the testing

of communication vehicles, the verification system, and the evaluation of the process of the pilot test.

Success indicators and criteria evaluated

We have developed a set of criteria to evaluate the pilot phase from a content perspective, taking

into account the following success indicators:

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4. Reduced costs for companies for the environmental analysis (compared to LCA)

Table 1 shows the criteria for evaluating the pilot phase from a content perspective.

Table 1. Criteria for evaluation.

Success factors Criteria

Number of pilots that manage to

deliver a complete PEFCR/OEFSR

A. Final draft PEFCR/OEFSR submitted to DG Environment

by 21 December 2016 or 31 January 2017

B. Completeness of PEFCR/OEFSR

Demonstrate that the methodology

works in any value chain

A. Harmonised method within product category/sector

B. PEFCR support fair comparison of products within the

same product category (same functional unit)

C. PEFCR/OEFSR enables product/organisation

improvements from an environmental point of view

Simplification compared to

conventional LCA

A. Existence of PEFCR/OEFSR simplifies compared to


B. Materiality principle simplifies PEF and OEF studies

C. Background data and models available for use in PEF

and OEF studies

D. Harmonization

Reduced costs for companies for the

environmental analysis

A. Reduced resources for a sector working together to

develop a PEFCR/OEFSR

B. Reduced resources for companies when a PEFCR/OEFSR

is available

C. PEFCR/OEFSR includes secondary data for all processes

D. SME tool is available

E. RPs and ROs models are available

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2 Evaluation results

Success indicator 1: Number of pilots that manage to deliver a complete PEFCR/OEFSR

Summary of findings

77% of all pilots submitted their final draft PEFCR/OEFSR to the EC by 31 January 2017. Since the EF

pilot phase is still ongoing, a final assessment of the completeness of the PEFCR/OEFSR was not

possible at the time of writing this report.

Detailed findings per criterion

1A. Final draft PEFCR submitted to SC by 21 December 2016 or 31 January 2017

Out of 26 pilots, 16 submitted their PEFCR/OEFSR to the EC by 21 December 2016 (62%), and an

additional 4 pilots submitted their PEFCR/OEFSR to the EC by 31 January 2017 (77%). Two pilots

were discontinued in 2016, the remaining four pilots have been delayed.

Two pilots were discontinued during the EF pilot phase:

Marine fish pilot was discontinued in June 2016. The pilot released a draft screening report and

a file consolidating comments from public consultations. These documents were endorsed by the

TS for marine fish. The TS for marine fish communicated the main reasons for not finalising the

PEFCR during the Steering Committee in June 2016, which are the following:

o Timing issue to finish the work within the foreseen timeline;

o Lack of background data regarding marine fish products, which makes it extremely

complicated to carry out a PEF study for products sourcing marine ingredients from

different parts of the world;

o Limited representativeness of the sector in the TS.

Coffee pilot was discontinued in October 2016. The pilot released a draft PEFCR, but this

document has not been officially endorsed by the TS for coffee. In a call with the Helpdesk, the

TS coordinator of the coffee pilot gave the following main reason for not finalising the PEFCR.

There was a fundamental disagreement in the choice of representative products among

stakeholders. The disagreement stems from a different understanding of the basis for product

comparison. All coffee can be compared or the coffee can be compared within one defined

technology (in this case a specific brewing method). It seems that the choice of the

representative products (benchmark) in this case can lead to different competitive advantages.

The stakeholders within the coffee pilot could not reach an agreement on this.

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1B. Completeness of PEFCRs/OEFSRs

Since the EF pilot phase is still ongoing, a final assessment of the completeness of the PEFCR/OEFSR

was not possible at the time of writing this report. The review of final PEFCR/OEFSR by the review

panels can indicate the completeness of the final PEFCR/OEFSR at the end of the EF pilot phase in

October 2017.

Success indicator 2: Demonstrate that the methodology works in any value chain

Summary of findings

The concept of PEFCRs and OEFSRs largely increases the harmonisation of PEF/OEF profiles, by

introducing the following elements:

Requirements for the Goal & Scope definition like functional unit and system boundaries

Data Needs Matrix

Requirements for modelling of common elements of product life cycles, like electricity and

disposal

Rules for modelling different life cycle stages

Default impact assessment categories and methods

It is expected that current development of EF-compliant datasets and RP/RO models will further

increase the harmonisation of PEF/OEF profiles.

The increased harmonisation of the PEF/OEF profiles largely contribute to fair product comparisons. A

few methodological issues need further attention and improvement to ensure fair product

comparisons:

The scope of the product category, or subcategory, covered by the PEFCR is highly relevant

for fair product comparisons. The scope of the product category shall be defined by choosing

the functional unit at such a level that all competing products sold at the European market

that fulfil the same functional unit are included. The EC is currently working on a procedural

guideline on how to identify the relevant granularity level of product groups. This guideline

will complement the current requirements in the PEFCR Guidance 6.0.

The impact assessment of toxicity need to be robust enough to support product comparisons

and benchmarking. The impact assessment method USEtox has its weaknesses which need to

be addressed. The Joint Research Centre is currently working on solutions regarding USEtox,

including the development of characterisation factors with alternative input data, and

expanding the list of characterisation factors in general.

The use and end-of-life stage of products should reflect the environmental performance of

products rather than differences in national conditions such as national electricity mix.

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Every PEFCR/OEFSR includes a list of mandatory processes for which primary data shall be collected.

In addition to this, a company can differentiate the environmental performance of its product by

using company-specific data instead of default secondary datasets for the remaining processes in

situation 1/other processes, and in situation 2 in the Data Needs Matrix. This freedom however also

gives the company the possibility to choose the data options that deliver the best environmental

performance. Verification shall therefore play an important role here.

The OEF method was tested by only two pilots which has led to limited experience in using the OEF

method. The issues flagged by PEF pilots during the pilot phase are largely also relevant for the OEF

method. However, some OEF specific topics, like the definition of the representative organisation, did

not receive special attention during the TAB. The pilot testing led to the insight that comparing

company‘s performance based on OEF studies is not useful.


2A. Harmonised method within product category/sector

During the extensive testing of the PEF and OEF methods during the pilot phase, it became clear that

the methods could be improved on several aspects. Under leadership of the EC, an impressive

number of technical issues (see Annex 1) has been picked up and discussed with experts in the TAB

meeting. Requirements were written down in issue papers which have been integrated in the PEF

Guidance 6.0. The consortium expects that such a rapid development of methodological

harmonisation would not have happened without the EF pilot phase and leadership of the

Environmental Footprint team of the EC. On the other hand, the continuous methodological

improvements created a substantial amount of work for the pilot TS. A more streamlined process with

less methodological improvements would have saved resources for the pilot TS, but it would not have

led to the same degree of methodological robustness.

Goal & Scope definition: PEFCR/OEFSR define the key elements from the goal and scope definition:

functional unit, system boundaries, Life Cycle Impact Assessment (LCIA) methodology, types and

source of data, data quality requirements, and allocation rules. This increases the harmonisation of

PEF/OEF profile results.

Data needs matrix: The use of company-specific and secondary data was flagged as an issue early

in the pilot phase and was under discussion for quite some time. When different secondary datasets

or company-specific data of different quality are used to create PEF profiles within the same product

category, the results can differ. These differences do not necessarily reflect the differences in the

environmental performance of products, but can be the result of the use of different data. The EC has

taken a deep dive into this topic and has dealt with it in a very constructive way. The data needs

matrix has been developed with various experts, including experts from the Helpdesk and the TAB.

The data needs matrix is a novel approach and provides detailed requirements on which data shall be

used in which situation. The “materiality principle” and the “influence of the company to obtain data”

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are integrated in this matrix in a structured way. The data needs matrix enhanced the harmonisation

of the PEF/OEF method tremendously.

Since the data needs matrix was introduced quite late in the pilot phase (discussed on the TAB

meeting in May 2015), it was applied to the pilots in a phased manner, depending on the progress of

each pilot. The data needs matrix is implemented by all pilots in the final draft PEFCR, but

implementation is not always in line with the PEFCR Guidance 6.0. The extent in which the data

needs matrix is implemented in the final draft PEFCRs varies largely per pilot.

Modelling of common elements in product life cycles: Product life cycles often include common

elements such as electricity, transport, packaging, and disposal. When these elements are modelled

in an inconsistent way, this can lead to double-counting or not counted impacts. The EC has picked

up this issue via working groups and issue papers addressing cross-cutting issues.

In 2014, the EC started the cattle model working group to ensure consistency in modelling cattle as a

common element of several PEF pilots: dairy, meat, leather, feed and pet food. The working group

had to come up with a common cattle model. Due to a lack of consensus, the JRC finally developed

one harmonised approach that has been applied during the pilot phase. The approach is however still

under debate and that is the reason why this section has not yet been included in the updated

version of the PEF Guidance and for delay in the delivery of the PEFCR for red meat products.

The packaging working group started in 2015 aiming at providing guidance on packaging related

modelling, including data issues, transport and end-of-life issues like re-use and recycling (PEF

Guidance 6.0, section 2.12). All the work aimed at ensuring consistency of packaging modelling

across pilots. Key topics covered were:

The definition of a list of background datasets to provide to pilots in order to model all the

packaging.

Work on the recycling rates values to be considered for the packaging at EU level and at

country level. This work ensures that all PEF studies will refer to the same source, unless a

more specific value is given within the PEFCR.

Rules to assess the average number of use or reusable packaging

One key point not covered within the packaging working group is the function of the packaging and

its influence on the rest of the life cycle, e.g. the shelf life. This issue is hardly addressed by any of

the pilots.

Throughout the pilot phase various End-of-Life formulae were tested by the pilots. In addition, three

workshops were organised in 2016 to discuss the End-of-Life (EoL) formula, later rephrased to the

Circular Footprint Formula (CFF), as included in Annex V of the PEF Guide (2013), and to find

alternative solutions. Multiple stakeholders participated in these workshops to discuss alternatives for

the formula. All stakeholders agreed on the need to develop a single formula but had different views

on some choices. The final requirements are included in the PEF Guidance (PEF Guidance 6.1, section

2.14).

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The Circular Footprint Formula (CFF) has three important improvements over the original End-of-Life

formula provided in the PEF Guide (2013):

The CFF introduces allocation factors for recycling and energy recovery to better reflect

market situations.

The CFF takes into account the quality of both the ingoing and outgoing recycled materials

instead of only the outgoing recycled materials.

The CFF includes specific parameters for heat recovery and electricity recovery instead of for

energy recovery in general.

These improvements were made because, amongst others, the original formula favoured the

incineration with energy recovery above recycling, due to the allocation of recycling benefits between

the life cycle that produces the recycled material and the life cycle that uses the recycled material

while the benefits of energy recovery were entirely allocated to the life cycle that sends material to

incineration. With the improved formula this issue is covered.

Other common elements were dealt with via issue papers and discussed in the TAB, including

agricultural processes (pesticide and fertilizer use and application), electricity, transport, and the use

stage.

The consistency of common elements in product life cycles may even be enhanced with the use of the

EF-compliant data purchased by the EC, because the modelling as well as data will then be consistent

for these processes.

Impact assessment: The PEF/OEF Guide (2013) specifies which impact categories shall be assessed

and which impact assessment methods shall be used for this. This is a major difference with LCA

standards like ISO 14044 where this is not made explicit. The specification leads to a more

harmonised method. However, critical comments were made that biodiversity was not included in the

default set of impact categories. Biodiversity is an endpoint indicator in LCA while all default impact

categories included in the PEF Guide are midpoint indicators. Biodiversity is therefore indirectly

addressed through these midpoint indicators. However, in some cases the method did not report

biodiversity as a hotspot, while it should have, like in the use of forests for paper. This resulted in

strong reactions from WWF and EEB and the paper industry, who were already investing much to

address this topic. An issue paper was written on how to address biodiversity in PEFCR/OEFSR. Pilot

TS could include biodiversity as a most relevant impact category in the PEFCR section “Additional

environmental information”, unless it can make clear it is not an issue. However, in practice very little

will be done with this information, as it does not influence the PEF/OEF profile score.

During the pilot phase, the impact assessment methods have been discussed and criticised a number

of times. The main concerns related to:

Mismatch between LCI and LCIA. The data in existing datasets do not always match the data

needed for some impact assessment methods. This was for example the case for land use. This

problem will be solved with the development of new EF-compliant datasets.

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Maturity of LCIA methods for certain impact categories was questioned during the pilot phase.

Therefore, the Joint Research Centre reassessed existing default LCIA models as included in the

PEF/OEF Guide that were considered as less robust or up-to-date and made suggestions for

necessary updates1, using the same criteria, and a few additional ones, as defined in the ILCD

Handbook2. The impact assessment methods of the following impact categories have been

discussed during the pilot phase and will be updated in the PEFCR Guidance: particulate matter,

land use, water scarcity, resource use (minerals), and resource use (energy carriers).

The impact assessment method for toxicity, USEtox, was criticized by pilot testers. The EC

therefore organised a workshop on the USEtox method at 15 January 2015 with the aim to gather

feedback from pilots on the use of USEtox in the screening study. From the workshop it became

clear that the model itself was not criticized as such but the input / output data were seen as

doubtful. USEtox was perceived as not robust enough for benchmarking and communication

purposes. This problem is not specific for the PEF/OEF method, but affects the pilots where

toxicity is one of the most relevant impact categories, e.g. copper production, decorative paints,

liquid washing detergents and PV electricity generation. This affects the product group chemistry-

driven products in general. The Joint Research Centre is currently working on solutions regarding

USEtox, including the development of characterisation factors with alternative input data, and

expanding the list of characterisation factors in general. JRC presented its approach in the TAB

meeting of March 2017.

2B. PEFCR support fair comparison of products within the same product category

This criterion assesses to what extent the PEF method supports comparability of PEF profiles. This

criterion is closely related to the criterion of harmonisation (2A), but focuses on elements of the

method that are of specific interest for the comparability of PEF profiles.

EF-compliant datasets: The major methodological improvements realised during the pilot phase

largely contribute to the harmonisation of PEF/OEF profiles which supports fair product comparisons.

The EF methodological requirements will be used consistently in the EF-compliant datasets which will

further increase the harmonisation of PEF/OEF profiles, strengthening the basis for fair product

comparisons even further.

Granularity: Granularity refers to the scope of the product category or subcategories covered by a

PEFCR. The scope of the product categories of the current PEFCRs is sometimes too narrow and

sometimes too broad which prohibits the comparison of products that compete at the same

commercial market. Moreover, the PEFCR development process can become difficult to manage in the

future when the scope of many PEFCRs is narrow, because a high number of PEFCRs may need to be

developed. Examples of developed PEFCRs with a narrow scope are: PV electricity (other electricity

generation technologies could have been included), and liquid washing detergents (washing powder

could have been included).

1 http://ec.europa.eu/environment/eussd/smgp/pdf/JRC_DRAFT_EFLCIA_resources_water_landuse.pdf

2 ILCD Handbook: Framework and requirements for LCIA models and indicators” EUR 24586 EN – 2010).

http://ec.europa.eu/environment/eussd/smgp/pdf/JRC_DRAFT_EFLCIA_resources_water_landuse.pdf

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It was hard to address this topic during the pilot phase, because the selected pilots could not be

easily enlarged during the pilot phase. The EC however addressed this topic for PEFCRs with a too

broad scope. The concept of subcategories was added to the PEF Guidance document. “When within a

product category several different applications are supported, several RPs may need to be identified.“

(PEF Guidance 6.0, section 2.1). In line with these requirements, the batteries pilot introduced five

product subcategories to take different battery applications into account, so batteries in cars cannot

be compared to batteries in laptops for example. Another nice example to manage the scope of a

PEFCR is the thermal insulation pilot. This pilot managed well to find a balance between keeping a

broad scope to avoid that the PEFCR would have limited applicability, as well as making specific rules

for specific applications. In order to do so, the thermal insulation pilot developed a PEFCR including

horizontal rules (overarching) and vertical rules (application specific). The horizontal rules provide the

framework in which future vertical rules could be developed. The approach resulted in a well-

structured and consistent PEFCR.

It is the question if the functional unit alone is sufficient for determining the scope of the PEFCR. After

all, the functional unit can be defined at a high level, but also at a detailed level, leading to different

scopes. The PV electricity pilot for example has formulated its functional unit as follows: “as 1 kWh

(kilowatt hour) of DC electricity generated by a photovoltaic module”. This supports fair comparisons

of PV electricity, but it does not allow for the comparison of gas-fired electricity or wind power

generated electricity with PV electricity, while this may be very worthwhile when one wants to

support the use of electricity with a low environmental footprint. Therefore, additional criteria could

help companies to choose a meaningful scope for their PEFCR. An additional criterion could be: define

the PEFCR scope based on the functional unit, choosing the functional unit at such a level that all

competing technologies sold at the European market that fulfil the same functional unit are included.

The EC is currently investigating this.

Normalisation for toxicity: As described under criterion 2A, the impact assessment method for

toxicity, USEtox, was criticized by pilot testers. In addition, normalisation factors of the three toxicity

impacts (human toxicity cancer effects, human toxicity non-cancer effects, and freshwater

ecotoxicity) do not reflect the actual European situation, due to data limitations on toxic releases in

national statistics (especially metals). Moreover, it is the question if a global reference situation is

preferable over a European reference situation, because supply chains often originate in countries

outside Europe. The Joint Research Centre is currently updating the normalisation factors of various

impact assessment methods, and develops normalisation factors using the global reference situation.

The normalisation of results is only an issue when products are compared based on normalised

results.

Weighting sets: During the pilot phase, the weighting for each impact category was equal. This

working procedure helped to park the weighting issue and to move forward with the pilot phase.

Weighting has been discussed during the pilot phase, among others in an expert workshop in

November 2015. Pilots were also allowed to test various existing weighting sets during the pilot

phase. Currently, JRC works on developing a weighting set (expected to be published in April 2017).

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Weighting sets inherently involve value choices. It is therefore possible that product comparisons

based on normalised and weighted results may be more intensely discussed by stakeholders.

Use stage and end-of-life conditions: The use stage and end-of-life of products should reflect the

environmental performance of products rather than differences in national conditions, e.g. national

electricity mix. Currently, the use stage and end-of-life stage are modelled in such a way that

country-specific conditions are taken into account. Ensuring fair product comparison would mean

considering the same use and end-of-life conditions for products sold in the same commercial

market. This can be done either at macro level by considering an average European situation for all

products (use stage and end of life) or at micro-level considering country specific situations, which

would require to duplicate the benchmark and make them country-specific.

Data needs matrix: The data needs matrix largely increases the harmonisation of used data among

products which enhances product comparability (see also criterion 2A).

2C. PEFCR/OEFSR enables product/organisation improvements from an environmental

point of view

This criterion relates to the flexibility in the PEF/OEF method. Flexibility in the method allows

practitioners to differentiate the environmental performance of products. This flexibility should not be

on the expense of the comparability of PEF profiles however (see 2B).

Data needs matrix: The data needs matrix (DNM) plays an important role in the way in which

companies shall calculate their PEF/OEF profile result. The DNM provides strict requirements which

enhance harmonisation in PEF/OEF profile results. On the other hand, the DNM creates flexibility

because a company itself determines to a large degree if they have access to company-specific data

when the activity is not run by the company. This allows companies to show the environmental

performance of company-specific processes and allows differentiating their product against those of

competitors.

Every PEFCR includes a list of mandatory processes for which primary data shall be collected. In

addition to this, a company can differentiate the environmental performance of its product by using

company-specific data instead of default secondary datasets for the remaining processes in situation

1/other processes, and in situation 2 in the Data Needs Matrix. This also gives the company the

possibility to choose the data that will result in the best environmental performance. Verification shall

play an important role here.

For many products, it is not easy to access company-specific data for processes far upstream or

downstream the product life cycle, because there is often no direct contact with these companies or

consumers. This largely determines on which basis products are compared. When the impact is the

highest in upstream or downstream processes, secondary datasets are used, and the products are

compared on differences in a few processes, e.g. the energy efficiency in the production plant of the

company carrying out the PEF study. This issue is relevant for pilots where the impact is the highest

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in upstream or downstream processes, e.g. detergents and coffee pilot. This was one of the reasons

for the Commission to introduce benchmark results excluding the use stage.

Success indicator 3: Simplification compared to conventional LCA

Summary of findings

The main aspects that contribute to the success indicator of simplification compared to conventional

LCA are presented below together with the benefit they bring.

Table 2. Overview of main aspects contributing to simplification compared to conventional LCA and

resulting benefits.

Aspects Benefits

Existence of PEFCRs and OEFSRs compared to


Less expertise needed to conduct a PEF/OEF study

Materiality principle It simplifies PEF and OEF studies because data

collection is focused on hotspots, not on

unimportant processes

Background data and models available for use in

PEF and OEF studies

Only collection of foreground and activity data is

needed

Harmonization It avoids confusion and debate It avoids confusion

and debate and thus lower costs of conducting the

PEF and OEF study.


3A. Existence of PEFCR/OEFSR simplifies compared to conventional LCA or PCRs

PEFCRs and OEFSRs are documents that determine how PEF and OEF studies need to be carried out

per product category or organizational sector. The PEF/OEF Guide and related PEFCRs/OEFSRs

provide much more specific guidance than the generic LCA guidance found in handbooks or general

standards. This leads to specific rules and many of the methodological and modelling choices have

been made in advance in these documents. For instance, a PEF study that will be executed on basis

of a PEFCR no longer needs to determine the functional unit or the allocation rules to be applied or

the default activity data and background datasets to be used because these have been defined in the

PEFCR. We also expect that less sensitivity analyses are needed because many of the methodological

choices have already been made. These pre-defined choices will make the process of conducting a

PEF or OEF study much simpler than if PEFCRs or OEFSRs didn’t exist. Also, this is likely to reduce the

effort and complexity of the review of PEF and OEF studies.

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Specific product category rules (PCRs) exist managed by different program operators (e.g.

Environdec) and for specific programs (like environmental product declarations, etc). That often

results in many PCRs for the same products available on the market. Although product category rules

(PCRs) have a similar objective to that of PEFCRs, they don’t reach the same result. The rules defined

in PCRs are often still too general, e.g. end-of-life allocation rules are not provided. The PEFCRs are

also unique in the very rigorous definition of the data quality requirements and the required

documentation and transparency of the data. Also, a unique aspect is that the PEFCR is not just a

document with guidance but is accompanied by a list of datasets to be used for secondary data (see

criterion 3C below). Finally, there is a big difference in the stakeholder involvement and the

acceptance: any party seems to be able to develop a PCR whereas a PEFCR can only be developed if

at least 50% of the market share of that product category is represented by those developing it. This

increases significantly its credibility.

Although the development of PEFCRs/OEFSRs will significantly reduce the efforts in carrying out PEF

and OEF studies, the development of a PEFCR/OEFSR is quite technical and labour-intensive. Of

course, this was particularly the case during the pilot phase because it was all work under

construction. We believe that developing future PEFCRs and OEFSRs post pilot phase will be quicker

and smoother but this is still a step that demands significant effort by all parties involved.

The main benefit resulting from the existence of PEFCRs and OEFSRs is that less experience and

expertise is needed to conduct PEF and OEF studies for which PEFCRs and OEFSRs exist. Limited

expertise can be partly solved with detailed guidance provided in PEFCRs and OEFSRs. For instance,

an applicant of a PEFCR does not need to know all possible end-of-life allocation rules nor to test

them all because one single formula for use is clearly specified in the PEFCR/OEFSR.

3B. Materiality principle

In conventional LCA studies a distinction is made between foreground and background systems,

which also determines what data to be collected, namely primary data for the first and secondary

data for the latter. In the Environmental Footprint initiative, two aspects have to be considered: 1)

materiality (i.e. focusing where it really matters, meaning that the data collection is to be focused on

the processes that contribute the most to the environmental performance of the product) and 2) the

level of influence (does the company applying the PEFCR run or have access to primary data for a

process?). With this approach, a company applying a PEFCR only needs to collect primary data for

mandatory company-specific data (this is determined in each PEFCR), and for data that they can

access and has a large contribution to the environmental performance (i.e. most relevant processes).

This provides, on the one side, a lot of clarity in what data is expected to be collected by the

company, and on the other side, a reduction of efforts to collect data compared to conventional LCA.

We also believe that this will lead to overall higher quality data being used in the PEF study and,

consequently, substantiating any claims made from it.

When it comes to the simplification success indicator, a downside of the data requirements in the

Environmental Footprint initiative is the need to (re)calculate the data quality score of many

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processes. While it sure makes sense to include this as a guarantee of a PEF study made with high

quality data, this requires extra effort in comparison to conventional LCA.

The main benefit derived from the materiality principle is that PEF and OEF studies can focus on

hotspots instead of spending a lot of time on less important processes as is often the case in

traditional LCA.

3C. Background data and models available for use in PEF and OEF studies

The availability of quality checked secondary data is a great simplification. In conventional LCA, any

LCA practitioner has to decide what secondary data to be used and from which source. Neither high

quality data can be guaranteed nor the consistency within and accessibility to these data. The EC is

currently purchasing EF-compliant datasets with a minimum data quality score and these will be

freely available to companies that will apply the PEFCRs and OEFSRs approved during the pilot phase.

These datasets will also be listed as the default secondary datasets to be used for all PEFCRs and

OEFSRs so a company applying these rules will know exactly what secondary dataset to use and

where to implement it in the model.

Another novelty in the EF pilot phase that leads to simplification is the access to the models of

representative products (RPs) and representative organizations (ROs). At the end of the pilot phase,

the Commission will make available the models of all RPs and ROs so that companies that apply

PEFCRs and OEFSRs also have a model to start with. This way, they don’t need to model from scratch

and, even if they do, for instance, if the software tool they will use is not able to make the models

available, the practitioner can re-build the model very easily using the model made available in Excel.

Availability of default secondary data and models is also likely to ease making a product portfolio

analysis within a company. For instance, from one product to another of the same product category

manufactured by the same company only specific activity data values for each need to be filled in,

e.g. the bill of materials and the mass of different materials going to end of life.

Availability of background data and models for use in PEF and OEF studies bring great benefits. Now,

only collection of foreground and activity data is needed and differences in results obtained for

different products can be attributed to differences in foreground and not in background data.

3D. Harmonization

Every company is looking for credible and robust sustainability metrics to use. So, a consensus

approach like the one resulting from the EF pilot phase avoids confusion and debate inside companies

and among other stakeholders (once it’s finalised, there was a lot of discussion within the pilot phase

and the development of the documents). Taking an existing consensual approach saves a lot of time

in the decision-making process at companies. It is also very important that many of the TS are being

coordinated by European branch associations because this reinforces the endorsement for the whole

industry at European level. This strengthens the applicability of the PEFCRs and OEFSRs in the future

by all member companies of the associations. All in all, we expect that it will be much easier to

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support an internal decision on a short notice as all is standardised, and that it will be faster to make

an external claim.

A harmonised and well-accepted methodology will be of great benefit to companies, the target

audience of the PEF results and to the LCA community at large as we believe that those parties will

stop debating the methodology and, instead, start competing on the results. Hopefully, this

transparency in the results will also lead to healthy competition towards better environmental

performance and, consequently, that each company starts improving their value chain with

sustainability in mind.

Success indicator 4: Reduced costs for companies for the environmental analysis

Summary of findings

This section assesses costs reduction for companies once the pilots phase will be finalized. This

analysis considers thus the foreseen October 2017 situation and not the situation at the time of

writing this report.

Reduction of costs mostly refers to time savings to perform a PEF/OEF study, and hence this section

has strong links with success indicator 3. Figure 1 gives a quick overview of the time savings for

conducting a PEF/OEF study depending on the guidance available for a sector. PEFCR/OEFSR, RP/RO

models and SME tools reduce the effort for performing environmental analyses by providing guidance

on goal and scope, data collection and life cycle impact assessment and providing default data.

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Figure 1. Reduced costs for companies for conducting a PEF/OEF study


4A. Reduced resources for a sector working together to develop a PEFCR/OEFSR

Developing a PEFCR/OEFSR is a time-consuming process which is done beforehand in order to save

time later on, when carrying out PEF/OEF studies. Wide involvement of companies, producing

products in the same product category, is required during the pilot phase to develop a PEFCR. The

Technical Secretariat must be representative of at least 51% yearly turnover. This means that many

companies, and thus possibly different interests, sit together. This rule has two opposite

consequences when considering financial aspects:

PEFCR/OEFSR development costs are supported by a large panel of companies, which limits the

cost per stakeholder.

Political discussions regarding strategic orientation within a technical secretariat may be time

consuming and delay the process.

Note that the technical secretariats involved in the pilot phase have faced many additional costs due

to the changing rules and expectations along the pilot phase. As the rules have now been defined,

the average time required to develop new PEFCR/OEFSR should be significantly lower than the time

spent on the development of the PEFCR/OEFSR within the pilot phase.

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4B. Reduced resources for companies when a PEFCR/OEFSR is available

As a guidance document, a PEFCR saves practitioners time by giving a well-defined framework, as

detailed in criterion 3A. In practice, three steps of a PEF study are especially affected:

Goal and scope definition: PEFCRs define the key elements from the goal and scope chapter from

usual LCA studies: functional unit, system boundaries, Life Cycle Impact Assessment (LCIA)

methodology, types and source of data, data quality requirements, and allocation rules.

RP/RO modelling: PEFCRs/OEFSRs will reduce time required at modelling stage by providing clear

guidance. Beyond this guidance, the availability of RP/RO models allows practitioner to already

have a model in the right format or to build it based on Excel models (see criterion 4D).

Life cycle impact assessment: PEFCRs have defined the most relevant indicators. This allows the

practitioner to save time by not analysing the non-relevant ones.

On the other hand, the strict requirements regarding calculation of DQR will increase significantly the

workload to perform a PEF study. Indeed, 3 of the 4 parameters from the DQR formula are context

specific, i.e. they have to be reassessed within the context of the specific PEF study. The DQR must

then be calculated for all the processes contributing to at least 80% of the single score impact.

4C. PEFCR/OEFSR includes secondary data for all processes

The list of background datasets to be used and their availability free of charge will allow two gains:

Time savings when building a PEF/OEF model, as detailed in criterion 3C.

Savings due to background dataset availability free of charge: Companies performing PEF studies

may save money due to the availability of background datasets free of charge. It is indeed

possible to perform a PEF/OEF study without any software or database license cost.

4D. SME tools available

SME tools will be available for a limited number of PEFCR (15%): beer, leather, olive oil, and t-shirt.

These tools will be accessible to non-experts, and will be simple and attractive. The software will be

open source, so that other pilots can reuse the code to build their own tools. The SME tool aims at

covering 90% of all software requirements for any PEFCR/OEFSR and to have a mechanism that

allows adaptations for particular PEFCR/OEFSR (plug-ins development).

In case such SME tool is available, the following costs savings are expected:

Time savings due to the availability of RP model ready to use with a user-friendly interface. No

time spent to model and integrate background datasets.

Financial savings as it is not needed to purchase any LCA software license nor commercial

database

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As the SME tools are not available at the time of writing this report, the specific features are not all

known yet. For example, DQR calculation might be part of the SME tool, which would also save time.

This means that the remaining work to complete a PEF study of a specific product refers mostly to

primary data collection and analysis of the results. Note that even if getting quick results will be very

easy, making it a PEF-compliant study will still need a minimum of LCA expertise.

4E. RPs and ROs models are available

RPs and ROs models will be made available for all the PEFCRs/OEFSRs developed within the pilot

phase by the Commission at the end of the remodelling process. These models will help reducing

costs of PEF/OEF studies, whoever carry out the study for the following reasons:

Lower expertise required to get PEF/OEF results, as detailed in criterion 3A.

Time savings due to the avoided modelling step, as detailed in criterion 3C.

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Annex 1. List of technical issues

The list below shows the technical issues that were addressed in the TAB meetings in the period

November 2013 – December 2016.

1. Representative product/organisation

2. Data Needs Matrix

3. Development of level 1 datasets by companies

4. Data quality assessment

5. Circular footprint formula

6. Agriculture modules

7. Green electricity

8. Biogenic carbon modelling

9. Use stage

10. Biodiversity

11. Impact assessment methods

12. Normalisation and weighting methods

13. Hotspot analysis

14. Benchmark calculations

15. Screening

technical evaluation of the eu ef pilot phase · 2017-09-18 · that the final pefcr/oefsr,...

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