The Integration of the PEF Method in the Ecodesign Directive

The Ecodesign Directive is assigned a prominent role in the sustainable product policy framework as a policy instrument prompting sustainable product design. Consequently, the Ecodesign Directive is under revision as within the upcoming Sustainable Products Initiative (SPI), to expand its scope and ensure that is delivers on circular design.
Concurrently, the Product Environmental Footprint (PEF) method finalised its pilot phase and entered the transition phase. In the transition phase its policy application is to be specified. The PEF method is a standardised lifecycle assessment (LCA) method, which should improve the comparability of LCAs by decreasing the flexibility in the methodological choices. Beside the PEF method, product specific category rules called (PEFCR) are developed for several product groups. The Ecodesign Directive also takes a lifecycle perspective and uses a simplified LCA method. Consequently, the PEF method could potentially play a role in the Ecodesign Directive. Therefore, the purpose of this study is to examine:
• Which aspects of the Product Environmental Footprint (PEF) can be expected to be implemented into the MEErP methodology in the future e.g., short, medium, and long term and how can this support material efficiency aspects?
The study is conducted based on a literature review and expert interviews. Furthermore, two case studies were conducted of the PEFCRs and preparatory studies for batteries and photovoltaic modules, inverters, and systems along with the Regulation concerning Batteries and Waste Batteries.

In the medium term, the PEF method and PEFCRs can be used as the methodological basis for the information requirements on the GER and GWP product declaration for PV modules, inverters, and systems and carbon footprint in the Battery Regulation. On the longer term, these information requirements could extend to performances classes and threshold requirements. Furthermore, the impact categories may be expanded from energy and CO2 emissions to also cover resources and water consumption. Finally, other product groups may also be coved by information, threshold and performance class requirements to the environmental footprint or ecological profile of the product. Thus, it will be based on a specific evaluation of the product or product group in question.
There are some limitations to the use of the PEF method in MEErP and its use as a methodological basis for a more systematic inclusion of environmental footprint or ecological profile in the design option. These are:
• Limited overlap between the product groups covered by PEFCRs and the Ecodesign Directive
• No guideline on how to use the impact categories from the PEF method in the ecodesign process
• Potentially high cost associated with conducting LCA studies
• Intellectual property rights of the EF datasets
• The PEF method and PEFCRs are not developed for this specific policy application.
The introduction of the simplified CFF and the recycling data into the EcoReport Tool will improve its ability to model recycling and the potential offsetting for recycling. Furthermore, the introduction of the PEF impact categories on “resource use” could also strengthen the focus on material efficiency aspects in the EcoReport Tool and MEErP. However, the introduction of elements from the PEF methods will not directly support other circular economy aspects, such as repairability, durability and upgradability. The current MEErP revision will introduce a new method to calculate and model durability including also upgrade and repair options. However, this method stems from the 4555x series of standards, and the repair index report developed by Joint Research Centre.