The PEFCR for Apparel and Footwear is the rulebook for running a Product Environmental Footprint (PEF) study on garments and shoes sold in Europe. Version 3.1 is the final text, dated 29 April 2025. The Commission lists it among its new PEFCRs.
At a glance:
Status: final, version 3.1 (29 April 2025)
Stated validity: to 31 December 2027, with Commission guidance indicating existing PEFCRs remain valid until EF 4.0 is implemented
Geography: EU-27, UK and EFTA
Scope: 13 product sub-categories, cradle to grave
Functional unit: one use of the product
Technical Secretariat coordinator: Cascale (formerly the Sustainable Apparel Coalition)
Last verified: 9 October 2026
What is the PEFCR for apparel and footwear?
It applies the general PEF method, set out in Commission Recommendation (EU) 2021/2279, to one product category. A Technical Secretariat coordinated by Cascale developed it, with Quantis as technical lead and 2BPolicy as facilitator. The voting members are mostly brands, industry associations and material bodies, including C&A, Décathlon, H&M, Inditex, Nike and Cotton Incorporated. The NGO ECOS takes part as a non-voting member, and the European Commission’s EF team and the European Environmental Bureau are observers.
The text went through two public consultations. The first ran from 7 July to 24 September 2021 and drew 996 comments from more than 80 organisations and individuals. The second ran from 18 March to 28 April 2024 and drew 5,119 comments from more than 250.
Is the apparel and footwear PEFCR mandatory?
It is a voluntary tool. The PEFCR itself says compliance is optional for in-house applications and mandatory whenever the results of a PEF study, or any of its content, are communicated.
Two communication limits matter. The PEFCR supports factual communication based on at least the four most relevant impact categories, or on additional environmental information. It does not allow the single score to be used in business-to-consumer communication, nor for comparison against the representative products. The review panel also asks users to follow the limits in section 3.8.1 closely when publishing comparisons.
Which products does it cover?
Thirteen sub-categories:
T-shirts
Shirts and blouses
Sweaters and midlayers
Jackets and coats
Pants and shorts
Dresses, skirts and jumpsuits
Leggings, stockings, tights and socks
Underwear
Swimwear
Apparel accessories
Open-toed shoes
Closed-toed shoes
Boots
Some products are out of scope. Exceptional pieces, meaning handicraft and haute couture items worn on specific occasions, are excluded. So are protective wear and cycling footwear. Workwear is partly covered: uniforms are modelled with the closest sub-category. Multi-part products, such as a suit, are footprinted part by part and summed.
What is the functional unit?
One use of the product, where a use is a 24-hour period regardless of how long it is worn. The reference flow is the fraction of the product consumed per use. The PEFCR gives the example of a T-shirt with a lifetime of 45 uses, where the reference flow is 1/45th of the T-shirt.
This changes how results read. A longer-lived product has lower production impact per use but more washes, so the use stage grows. Products that fail the baseline quality requirements carry a higher impact per use.
How do durability and repairability affect results?
The PEFCR estimates product lifetime from three things: intrinsic durability, extrinsic durability and repairability. Intrinsic durability comes from standardised tests and feeds an intrinsic durability multiplier (IDM). Repairability feeds a repairability multiplier (RM), built from the repair cost ratio, spare parts, repair services and “right to repair” communication. Extrinsic durability is held at a multiplier of 1 for now.
The review panel notes that footprint results will be largely influenced by the IDM and RM. It asks that verification teams have apparel and footwear expertise, and that a future version improve the treatment of extrinsic factors.
Which life cycle stages and impact categories does it use?
It is a cradle-to-grave method: raw materials acquisition and pre-processing, manufacturing, distribution, use (washing, drying, ironing and footwear care) and end of life. End of life and recycled content use the Circular Footprint Formula.
The PEF profile reports the EF impact categories, 16 in total, and the PEFCR identifies the most relevant ones per sub-category. The EU Textiles Ecosystem Platform notes that the biggest impacts often come from fibre production, consumer care (especially drying) and end-of-life treatment.
One addition goes beyond the standard categories. The PEFCR includes a fibre fragment calculation for impact on marine biota, reported as additional environmental information. It treats microplastic shedding only partially, and biodiversity is not covered.
What data do you need?
The PEFCR uses a Data Needs Matrix that sets which data must be company-specific and which can come from secondary datasets. Mandatory company-specific data points include the bill of materials, assembly losses and unsold consumer products. Section 5.1 lists the full set. The review panel acknowledges these requirements reflect current limits on raw material traceability, and expects a future version to consider more specific data.
Secondary data must be EF-compliant where available. The Commission’s transitional guidance of 14 July 2026 covers cases where EF-compliant datasets are limited during 2025 to 2028. It states that the guidance does not apply to studies carried out under a valid PEFCR, and that existing PEFCRs remain valid until EF 4.0 is implemented.
How is a PEF study verified?
Section 8 sets verification requirements for studies run outside a tool and for studies run in a pre-verified tool, including extra checks on the IDM and RM. Because those multipliers move results so much, check that your verifier has apparel and footwear process expertise.
What should brands do now?
Find your sub-category in the PEFCR and check the exclusions.
Collect your bill of materials and the mandatory company-specific data.
Plan intrinsic durability testing and document your repair offer.
Decide whether to run the study in a pre-verified tool or standalone, and plan verification.
Confirm the current validity position and watch for the EF 4.0 update.
How does it connect to other EU rules?
The PEFCR treats unsold consumer products as part of the raw materials stage. That sits alongside the Commission’s February 2026 measures under the Ecodesign for Sustainable Products Regulation on the destruction of unsold apparel and footwear. From 27 September 2026, Directive (EU) 2024/825 also restricts generic environmental claims, which raises the value of a method that defines how claims are substantiated.
