So You Want to Be a Sustainable Brand? Here's the EU’s 100-Page Rulebook You’ll Actually Have to Follow
🧵 This post is part of a weekly series unpacking sustainability news, fashion policy, and the stories shaping our future wardrobes. Subscribe for more.
So You’ve Switched to Organic Cotton. That’s Cute.
Now Meet the EU Rulebook.
You’ve swapped polyester for bamboo, added “climate neutral” to your checkout page, and partnered with a zero-waste influencer. Congratulations, you’ve done sustainability the Instagram way.
Now comes the EU way. It’s less #consciousaesthetic and more spreadsheet wizardry.
As of this year, if you're selling clothing or shoes in Europe and want to make claims like “eco-friendly” or “climate positive,” you’ll need to comply with a monster of a document:
👉 Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear v3.1
It’s 100+ pages of tests, templates, transport data, and tear strength protocols. Not sexy, but critically important.
What Is the PEFCR?
The Product Environmental Footprint (PEF) is the European Commission’s official framework for measuring a product’s environmental impact across its entire life cycle, from raw material to landfill (or, if you're lucky, someone’s Depop cart).
The PEFCR is the category rulebook for the fashion industry. The most recent version (3.1, released April 2025) tells brands:
How to calculate their climate and water impact
What counts as durability
How to model circularity
Which fibers are considered resource-heavy
And no, you can’t just Google your way through it. It includes mandatory test protocols, impact weighting charts, and data submission templates that make your average LCA look like kindergarten math.
Who Needs to Read This?
Sustainability managers 🧑💼
LCA consultants 📊
Product developers 🧵
Legal & compliance teams 📜
Designers picking materials 🎨
Marketing teams crafting claims 🚫 (no more greenwashing, please)
If you're launching a product in Europe with any environmental messaging, this affects you.
The Key Shift: Durability Now Impacts Your Score
One of the biggest changes in version 3.1?
Your product’s physical durability directly affects its environmental score. Finally.
That means if your cotton tee pils after three washes, you get a worse footprint. If your zippers break or seams slip, your “sustainable” hoodie takes a hit.
The EU even provides detailed testing thresholds, by product type, to define what counts as basic, moderate, or aspirational durability.
Want to see what they’re grading you on? Check out:
📄 Annex V – Detailed Durability Requirements
What You Need to Report
PEF-compliant studies must cover:
All materials (down to labels and trims)
Waste from cutting and production
Packaging, shipping, e-commerce returns
Care instructions (yes, washing temperature matters)
End-of-life fate (landfill? incineration? resale?)
Microfiber pollution potential 🧫
And all of it must be backed by real, traceable, and often lab-tested data. Think ISO standards, not vibes.
For your LCA team:
📄 Annex II – PEF Study Template (DOCX)
📄 RP Study – Real Examples for 13 Product Types
So What’s the Point?
The point is accountability. If you’re claiming to be low impact, you need to prove it. The PEFCR is:
A tool for standardizing LCAs
A defense against greenwashing lawsuits
The blueprint for the EU Green Claims Directive (coming soon)
The foundation for product labels and scoring systems (coming fast)
Eventually, this may be what retailers, platforms, and consumers use to compare your product to others—like a sustainability nutrition label.
TL;DR
🧷 The EU has released a new official rulebook for calculating the environmental footprint of fashion products.
📊 It’s technical, detailed, and—yes—legally important.
🧵 Durability and design choices matter more than ever.
📣 If this kind of data doesn't back your sustainability claims, they may not be legal for long.
This isn’t just about compliance. It’s about doing better—and proving it.
Stay tuned. I’ll be digging deeper into what this means for secondhand platforms, textile recyclers, and emerging designers in future posts.
🔗 Useful Links:
I really hope you're enjoying The Sustainability Pulse, my weekly newsletter looking at sustainability in the fashion industry. If you find the tips and insights useful, please share these articles to help spread the word.