Product Environmental Footprint (PEF) and MEErP (GEN - 1248.00)

DG Environment training session

GEN - 148.00. The European Commission DG Environment proposed the Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF) methods as a way of measuring environmental performance. The initial ideas were developed in the 2010s, under the 2020 Circular Economy Action Plan (CEAP) and the current consultation on the Sustainable Products Initiative (SPI). It looks like PEF may possibly fit in future legislation.


Over the period 2000-2010, the Commission has funded various studies into the environmental impact of products and organisations.  At the end of 2010 the European Council invited the Commission to develop a common methodology on the quantitative assessment of environmental impacts of products, throughout their life cycle. This was coupled to an assessment of labelling products so that consumers would make reasoned choices as it is not possible for them to distinguish among 230 different environmental labels in Europe.

PEF (and others)

PEF is a methodology that quantifies all environmental impacts over the life cycle of a product and would be supplemented with product category-specific rules.

It sits alongside other methodologies that also assess life cycles, for example within the Eco Report Tool used in the Methodology for Ecodesign of energy-related products (MEErP), Environmental Product Declarations and others.

Alongside PEF other methodologies are being developed. For example, the Circular Footprint Formula (CFF) that models on one side the recycled content of products and on the other side the end-of-life of materials, through landfill, incineration and recycling.

Except for batteries all pilot cases have been related to consumer goods hat is the difference between EPD, LCC, LCA and the like following European definitions

None of the PEF pilot cases relate to HVACR.

Training sessions

On 27 May, the European Commission held a training webinar on the Product Environmental Footprint (PEF) that attracted around 700 participants. These sessions are oriented towards Small and Medium-sized Enterprises (SMEs).

This was the first training and similar trainings would be organised in the future by the Commission The slides presented during the webinar, recording and a Q&A document will be made available in the near future on the Commission DG ENV website:

Thanks to Orgalim, a copy of the presentation is included as GEN – 1248.00.


The expectation is that PEF would be integrated in environmental policies, such as CEAP, SPI, Green Claims Initiative and might well be integrated in to the revised Ecodesign framework directive.

Because a multitude of DGs is involved in the different policies it is difficult to assess how and when PEF would figure in legislation related to HVACR equipment.

In the view of DG Environment, the future policies would have to rely on Life Cycle Assessments.

Related - MEErP review

The first stakeholder meeting for the revision process of the Methodology for Ecodesign of Energy-related Products (MEErP) will take place on 24 June 2021, 09:30-12:30h.

The purpose of the meeting would be to present and discuss progress made in Task 1 (updating of the Eco Report Tool) and Task 2 (material efficiency aspects) of the revision.

On 02 June 2021, the MEErP project website still included the 12 November 2020 presentations and did not contain any new documents.

However, because during the 12 November webinar, PEF was mentioned, it is possible that some ideas from the PEF methodology may find their way in the Eco Report Tool.

The agenda and meeting documents will be disseminated close to the meeting date. One can register to this meeting by requesting an invitation from by 16 June.

Recommended actions

It is not possible to guess how the discussions on sustainable product policies will evolve.

For the HVACR industry it would make sense to maintain the ecodesign approach. The MEErP has proven to be quite stable over the past 15 years and it could make sense to stick to it rather than moving towards a PEF for which no evidence is available.

The members are encouraged to register for MEErP stakeholder meeting on 24 June 2021.

Related documents and links

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