Product Environmental Footprint (PEF) Pilot Phase-Comparability over Flexibility?

The main goal of the European product environmental footprint (PEF) method is to increase comparability of environmental impacts of products within certain product categories by decreasing flexibility and therefore achieving reproducibility of results. Comparability is supposed to be further increased by developing product category specific rules (PEFCRs). The aim of this paper is to evaluate if the main goal of the PEF method has been achieved. This is done by a comprehensive analysis of the PEF guide, the current PEFCR guide, the developed PEFCRs, as well as the insights gained from participating in the pilot phase. The analysis reveals that the PEF method as well as its implementation in PEFCRs are not able to guarantee fair comparability due to shortcomings related to the (1) definition of product performance; (2) definition of the product category; (3) definition and determination of the representative product; (4) modeling of electricity; (5) requirements for the use of secondary data; (6) circular footprint formula; (7) life cycle impact assessment methods; and (8) approach to prioritize impact categories. For some of these shortcomings, recommendations for improvement are provided. This paper demonstrates that the PEF method has to be further improved to guarantee fair comparability.