Comments on Product and Organisational Environment Footprint methodologies (PEF/OEF)

Orgalime, representing Europe’s Technology Industries, appreciates the opportunity to comment on the Product and Organisational Environmental Footprint methodologies following Commission recommendation 2013/179/EU and the selected pilot case studies carried out on their basis. 

Orgalime supports the use and development of reliable, coherent, understandable, and verifiable environmental information. The existing situation with more than 100 active environmental labels in Europe alone seems far from ideal or efficient to advance common EU policy measures and reach a joint objective. All these options on the other hand can enable customers to choose and prioritise the environmental issue that they consider to be most important and relevant for them. The PEF (Product Environmental Footprint) and OEF (Organization Environmental Footprint) could, under the right circumstances, be a helpful tool; however more development would be needed and important barriers would have to be removed.

Orgalime recommends that the use of the PEF and OEF Guidance remains voluntary and suggests making a thorough impact analysis with proper stakeholder involvement. This could be performed with a multi-stakeholder approach that considers existing initiatives and aims to explore how the PEF would overlap or complement existing systems. Orgalime remains available to contribute to such a process. 

Orgalime also underlines the importance of international collaboration to enable comparison of all actors in a given supply chain. To ensure harmonisation any further development of the PEF should be led by standardisation organisations. To make PEF workable and support Europe’s sustainability agenda international harmonisation is required.

Please download the document to read the comments in full.