Product Environmental Footprint (PEF)

Position

Product Environmental Footprint (PEF): What is important now is to draw right conclusions from the pilot projects!

Product Environmental Footprint (PEF): what is important now is to draw the right conclusions from the pilot projects!

Federation of German Industries e.V.

Date: 16.11.2017

Product Environmental Footprint (PEF)

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In its position paper “Structure Product Environmental Footprint (PEF) sensibly and consistently” of 11 May 2015 (BDI position paper D 0689), BDI set out clearly that there are serious methodological deficiencies in the way the Product Environmental Footprint (PEF) is calculated and put forward concrete proposals for improvement so that PEF can be developed into a multicriteria lifecycle-based approach enabling an analysis of the environmental impact of products and services.

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The European Commission’s failure to specify its intentions regarding the future use of the PEF continues to constitute a serious obstacle to further development of the PEF methodology. The result is considerable uncertainty for industry. Possible areas for use of the PEF are public procurement, consumer information for the purpose of product comparison as well as identification of product-related environment-relevant hot spots.

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Many industrial companies have supported the detailed work of the 24 pilot projects with experts and a great effort has been made to help identify a workable PEF methodology. As a result, some important criteria for the principles of this methodology such as the reliability and representativeness of data have been delivered. But one of the most salient learnings is a recognition that the current status of the PEF methodology and the quality of the available input data are not ripe for a broad and routine rollout. Because it is not clear to what extent the results of a PEF assessment reflect real environmental impacts.

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Product Environmental Footprint (PEF)

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In this context, the planned summery of the previous numerous pilot projects in seven artificial clusters seems counterproductive, as only these clusters are involved in the further political process within the framework of the IPP/CSP Working Group.

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Many deficiencies in the PEF methodology have still not been sorted out. This applies in particular to how benchmarks are determined and the weighting assigned to effects. In any event, effects cannot be weighted purely on a scientific basis; they always presuppose political value judgments. But other practices such as the use of “weighted average values” to calculate emissions down to several decimal points are likely to produce questionable results. In addition, the determination and/or definition of system limits for some of the pilot projects is unsatisfactory. To this is added the fact that the failure to distinguish between products, by-products and waste, together with the first two being deemed equivalent in some pilot projects, has the effect of discriminating against recovery of by-products, a situation which can over time lead to considerable negative consequences for the recycling sector in question.

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There are therefore doubts as to whether the European Commission can achieve a consistent added value that can be delivered in practice with the current PEF approach as compared with the existing and established environment-related product assessment instruments (e.g. environmental declarations in the construction sector).

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Harmonised weighting of effect categories only makes sense if it is applied as a function of its relevance for the product groups in question. To this end, the results of the PEF pilot projects should be further developed on a scientific basis with the involvement of industry and fed into the ISO standardisation process as and when appropriate. But the limits of the PEF methodology must also be clearly analysed and presented, necessarily addressing the deficient definition of the entire purpose of the project.

Federation of German Industries Member Association of BUSINESSEUROPE

Address Breite Straße 29 10178 Berlin Postal Address 11053 Berlin Germany Contact Franz-Josef von Kempis T: +493020281509 F: +493020282509 Internet www.bdi.eu E-Mail V.Kempis@bdi.eu

Product Environmental Footprint (PEF)

About BDI The Federation of German Industries (BDI) communicates German industries’ interests to the political authorities concerned. She offers strong support for companies in global competition. The BDI has access to a widespread network both within Germany and Europe, to all the important markets and to international organizations. The BDI accompanies the capturing of international markets politically. Also, she offers information and politico-economic guidance on all issues relevant to industries. The BDI is the leading organization of German industries and related service providers. She represents 36 inter-trade organizations and more than 100.000 companies with their approximately 8 million employees. Membership is optional. 15 federal representations are advocating industries’ interests on a regional level.

Imprint Federation of German Industries e.V. (BDI) Breite StraĂ&#x;e 29, 10178 Berlin, Germany www.bdi.eu T: +49 30 2028-0 Contact Franz-Josef von Kempis Referent Telefon: + 49 (30) 20281509 v.kempis@bdi.eu BDI document number: D 0879

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