PEF and OEF evidence for EU Green Claims substantiation

No. The Commission proposal does not require PEF or OEF for every Green Claims substantiation file. It sets general criteria instead of prescribing one assessment method for every environmental claim because a single footprint method does not cover every claim type.

The Council general approach is more specific about their value: it recommends Environmental Footprint methods where they are complete for the relevant impacts and where Product Environmental Footprint Category Rules (PEFCRs) or Organisation Environmental Footprint Sector Rules (OEFSRs) have been established. Recommendation (EU) 2021/2279 remains a recommendation unless another applicable rule makes a method mandatory.

They help when the claim needs life-cycle evidence rather than a single attribute record. The Environmental Footprint overview describes PEF and OEF as EU-recommended LCA-based methods that quantify environmental impacts across supply-chain activities, from raw-material extraction through production, use, and final waste management.

That evidence fits Green Claims criteria requiring recognised scientific evidence, accurate information, significant impacts from a life-cycle perspective, and checks for trade-offs. A PEF or OEF study can therefore support the substantiation assessment, the public summary of the claim, and the verifier's review, provided the study boundary and data are aligned to the actual claim wording.

The current Environmental Footprint method uses a default set of 16 impact categories. They include climate change, particulate matter, ionising radiation, photochemical ozone formation, acidification, ozone depletion, terrestrial, marine, and freshwater eutrophication, freshwater ecotoxicity, human toxicity for cancer and non-cancer effects, land use, water use, and resource use for minerals, metals, and fossil resources. A claim about one result should not imply that every category improved.

The evidence file should make the claim reproducible. For a product claim, preserve the PEF study scope, functional unit or reference flow, system boundary, life-cycle stages, datasets, assumptions, allocation choices, use-stage and end-of-life modelling, data-quality rating, and version of any PEFCR used. For an organisation claim, keep the equivalent OEF boundary, activities, facilities, value-chain coverage, datasets, assumptions, and sector-rule references.

The Green Claims text distinguishes primary information collected by the trader from secondary information from other sources. Keep primary data where the trader has it for the environmental characteristic claimed, and document why any secondary data is representative of the product or organisation value chain.

Category and sector rules matter when they exist for the product or organisation behind the claim. PEFCRs and OEFSRs narrow the method from a general Environmental Footprint framework into product-category or sector-specific rules, improving comparability across studies that would otherwise make different boundary, dataset, benchmark, or modelling choices.

For comparative claims, that discipline is especially important. The Green Claims proposal requires equivalent information and data, equivalent value-chain-stage coverage, and equivalent coverage of significant environmental characteristics for products or traders being compared. Under the Environmental Footprint methods, comparisons and comparative assertions require an applicable PEFCR or OEFSR; using the same rule also helps show that the comparison was not built on asymmetric boundaries.

The common mistake is treating a footprint study as proof of any green claim. A PEF result may support a claim about life-cycle environmental performance, but it does not automatically substantiate separate claims about repairability, durability, recycled content, organic production, biodiversity outcomes, or offset-based climate messaging.

Before publishing, compare the claim wording with the study boundary and impact categories. If the claim says more than the PEF or OEF study measured, narrow the claim or add separate substantiation for the missing environmental characteristic.