The ongoing pilot phase of the European Product Environmental Footprint (PEF) tests the PEF method and develops product category-specific rules (PEFCRs) for selected product categories. The goal of PEF is to address all relevant environmental impacts and the full life cycle of products is acknowledged. However, PEF faces several methodological and practical challenges. This paper presents key findings of a comprehensive analysis of the current status of the PEF pilot phase (mainly based on the evaluation of all draft PEFCRs). Remaining key challenges are: (1) the still open goal and policy outcome of the PEF process; (2) the difficult applicability and, thus, the unclear tangible added value of some PEF rules compared to current life cycle assessment (LCA) practice; (3) the insufficient maturity level of some predefined impact assessment methods and missing reliable methods for prioritizing impact categories; and (4) the fact that, in the worst case, the developed PEFCRs may not support a fair comparability of products. This “mid-term review” of the PEF pilot phase shows that the PEF method and the PEFCRs need to be further improved and refined for a successful policy implementation of PEF, but also for avoiding that unsolved issues of PEF affect the LCA method as such.
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