The Product Environmental Footprint (PEF), is a comprehensive Life Cycle Assessment (LCA) methodology for quantifying the overall environmental impact of products, whether they are goods or services with a focus on reliability, reproducibility and comparability of the results. The European Commission proposed and recommended the Product Environmental Footprint (PEF) and Organisation Environmental Footprint (OEF) methods as a common way of measuring environmental performance (EU Commission Recommendation 2021/2279). In its 2019 communication on the European Green Deal, the Commission announced legislative and non-legislative efforts to reduce the risk of false green claims (greenwashing), including by requiring companies to substantiate environmental claims about their products with a standard methodology to assess their impact on the environment. The PEF is a more prescriptive method compared to other existing methodologies and international standards to enhance the reproducibility and comparability of results across the entire value chain. Thus, is helping companies to calculate the environmental performance of their products, based on specific, reliable, and verifiable information to combat greenwashing and enable fair and performance-based green claims. This approach enables informed decision-making to reduce environmental footprints. Achieving comparability requires adherence to the same Product Environmental Footprint Category Rules (PEFCR) (EPLCA 2018 & European Commission 2021a). For more information on the PEF, visit the website of the European Commission on the PEF method.

The environmental impact is measured in relation to the functional unit. In the case of this project, an overnight stay in a hotel room is considered the unit of measurement (European Commission 2021a). Under the PEF-method, the Functional Unit should comprehensively describe the function(s) and lifespan of the product or service, considering how each aspect of the unit can affect the environmental footprint of the product or service. 

Each impact category result is communicated using its own unit:

• Climate change: kg CO2-eq

• Ozone depletion: kg CFC-11-eq

• Human toxicity, cancer: CTUh

• Human toxicity, non-cancer: CTUh

• Particulate matter: disease incidence

• Ionising radiation, human health: kBq U 235 -eq

• Photochemical ozone formation, human health: kg NMVOC – eq

• Acidification: mol H+ – eq 

• Eutrophication, terrestrial: mol N -eq

• Eutrophication, freshwater: kg P – eq

• Eutrophication, marine: kg N -eq

• Ecotoxicity, freshwater: CTUe

• Land use: pt

• Water use: m3 world -eq

• Resource minerals and metals: kg Sb – eq

• Resource use, fossils: MJ

The overall PEF study provides an aggregated single overall score in absolute values expressed in points.

Yes, the impact of climate change, in particular the carbon footprint, is generally included in the analysis. However, there may be exceptional cases where the carbon footprint of certain products is not relevant.

Yes, the impact of water usage as well as the product’s emissions to water are generally included in the analysis. This impact is generally relevant for agriculture products or material productions for instance. 

The Product Environmental Footprint Category Rules (PEFCR) are specific guidance, additional to the general guidance provided with the PEF method, see also our glossary down below. They are tailored to specific product categories andaddress the entire life cycle of a product or service, e.g. an overnight stay in a hotel. These rules add detail to the general guidelines for PEF studies. by concentrating on key aspects and factors and make study results more relevant, reproducible, consistent and comparable. PEFCRs aid companies to implement PEF studies because they reduce effort and costs by defining what matters most for a specific product category and taking methodological choices that can be still open in the general PEF method. They provide a template model to adjust to specific product/service (e.g. a hotel).. PEFCRs are written in a way that is understandable to those with expertise in both life cycle assessment (LCA) and the product category. This will ensure that they can be effectively used to conduct PEF studies (EPLCA 2018).

A Product Environmental Footprint (PEF) study in compliance with a PEFCR is projected to reduce of the cost associated with a conventional Life Cycle Assessment (LCA) by providing a comprehensive set of rules which allow for a faster, reproducible and robust assessment. Additionally, the PEFCR aims to ensure scalability by defining the minimum set of value chain data necessary to establish a meaningful and comparable product footprint. 

The basis for the development of the PEFCR and PEF in general is outlined in the “Recommendation on the use of Environmental Footprint methods” by the European Commission (europa.eu). The document provides the framework for the implementation and utilization of environmental footprint methods within the European Union. It establishes guidelines to ensure consistency. The recommendation serves as a guiding document for policymakers, businesses, and stakeholders that want to apply the PEF method or develop PEFCRs, such as the PEFCR for hotel accommodation services project.

In principle, the PEF method can be applied for all sectors, products and services. However, the specific product rules (PEFCR), which facilitate the application of the method, were so far developed for about 20 product categories (see full list here), while there are more currently under development: apparel and footwear, synthetic turf, marine fish, cut flowers and potted plants, hotel accommodation services. More recently, two new PEFCR developments on Aircraft, unmanned aerial vehicles (UAVs) and Drones as well as on Space have been started.

The tourism ecosystem represents 6.6% of the EU Gross Value Added in 2022, reaching over 10% in some countries, and employs over 20.4 million persons (9.5% of EU employment) Transition pathway for tourism - Publications Office of the EU (europa.eu).  Thus, “greening” the tourism sector is a central component of the overarching sustainability transformation of the European Union. A key component of this transformation is the development of reliable and standardised methods to measure, compare and reduce the environmental impact of products and services in the tourism sector (in this project: hotel accommodation services) ─ and to communicate the environmental impact to consumers.

The PEF is particularly relevant in enhancing credibility and transparency of environmental claims issued by businesses. The PEF method is recognised in the Commission proposal for the Green Claims Directive. Whenever a PEFCR is developed, the PEF studies should be performed in compliance with the PEFCR and not the general PEF method. Thereby, the PEFCR enable hotels to substantiate their environmental claims, improve operations and effectively improve the sustainability of hotels. 

So far, many labels and certifications have been developed and more are being added, leading to confusion for both businesses and consumers. The PEF can be the response to the demand for credibility via harmonisation, industry-wide recognition, and achieving comparability. The PEF Category Rules (PEFCR) enable hotels to assess and communicate their environmental impact on the basis of a reliable, science-based method and thus avoid greenwashing (EPLCA 2018). 

Click here to get an overview of all the benefits of the PEFCR for Hotel Accommodation Services.

The Green Claims Directive (GCD) is still not adopted, therefore it is not known what the final requirements will be. According to the current public draft, the PEF method is recognised as a method suitable to substantiate green claims. The PEF method provides a robust, science-based framework that enhances consistency and comparability across the industry. This aligns well with the objectives of the Green Claims Directive, which aims to ensure that environmental claims are reliable and transparent.

Provided the above is not changing and assuming a PEF study under the Hotel accommodation PEFCR is fulfilling all related requirements, hotel owners would be enabled to communicate compliance with the national legislations in the relevant EU member state, as to be still developed from the Green Claims Directive, by conducting PEF studies that quantify their environmental impacts. These studies should then adhere to the specific rules outlined in the PEFCR, which are being developed to support the EU hotel industry in substantiating their sustainability efforts effectively.

The Corporate Sustainability Reporting Directive (CSRD) aims to enhance and standardise sustainability reporting across companies, ensuring transparency and comparability of environmental, social, and governance (ESG) information. The PEFCR for Hotel accommodation is being created to help hotels assess and report their environmental impacts. This aligns with the CSRD's focus on detailed environmental reporting. Hotels need to report specific indicators like material usage and waste, which are mostly gathered during a PEF study, requiring only minor additions. These indicators can then be used for CSRD reporting. Other CSRD requirements, like future plans, are also needed. The PEF study can help with these by providing a model to explore changes in hotel operations. 

Moreover, by providing this data, hotels enable their corporate clients to incorporate accurate environmental impact information due to business travel into their own CSRD reporting. For instance, hotels can offer their business travel customers detailed reports on the CO2 scope 3 emissions associated with their stay. 

Recently, the European Commission adopted an "omnibus" package of proposals aimed at simplifying rules, including those related to sustainability reporting under the CSRD. This initiative is expected to deliver over €6 billion in administrative relief across the EU. The simplification of rules is intended to streamline sustainability reporting and EU investments, making it easier for businesses, including hotels, to comply with the CSRD requirements. As the CSRD is transposed into national law, hotels should remain informed about how the directive is adopted in their respective countries, as national regulations may introduce specific reporting obligations or timelines that impact their compliance strategies. We will continue to update our Q&As here to reflect these changes and provide the latest information to assist hotels in navigating these developments effectively.

In the case of this project, an overnight stay in a hotel is considered the unit of measurement.

Updates on the project will be published on this website under 'News' and on the PEF LinkedIn channel. Additionally, you can subscribe to our regular update here to receive regular updates.

PEF Category Rules (PEFCR) will be developed in the time period from 2024 to 2026. After the European Commission approves the finalisation of the PEFCR, they can be applied by the hotel accommodation sector in form of PEF studies. See here for the complete timetable.

The project is mandated by the European Commission. The Technical Secretariat (TS) is the governing body that is developing the PEF Category Rules (PEFCR). It will meet periodically to make technical decisions, discuss the progress made, and organise hotel industry testing of the draft PEFCR. The TS is a multi-stakeholder working group, representing at least 51% of the EU hotel market. Click here to see all members of our TS.

Within the development process, there are two public consultations. Stakeholders, suppliers, civil society, policymakers, and institutions are invited to comment on the PEFCR to ensure the credibility and transparency of the process. Furthermore, the TS includes not only representative accommodation companies but also an environmental NGO.

The scope of this PEFCR is defined by the NACE code '55.10 - Hotel and similar accomodation': provision of accomodation, typically on a daily or weekly basis, principally for short stays by visitors. This includes the provision of furnished accomodation in guest rooms and suites. Services include daily cleaning and bed-making. The scope includes hence accomodation provided by: hotels, resort hotels, suite/apartment hotels, motels.

The fully life cycle (cradle to grave) for the hotel accomodation service is within the scope of this PEFCR.

Services like food and beverage, parking, laundry not related to rooms, pools, gyms, and conference facilities are not included in the PEFCR for hotels because they fall under different industry codes. For more details on exclusions, check the 'scope' section in the draft PEFCR. This setup focuses on assessing the environmental impact of accommodation services, which is common to all hotels. Including other services would greatly expand the project's scope to cover different industries like restaurants and spas, requiring separate PEFCRs for each.

Focusing solely on accommodation allows fair comparisons between hotels, as some have restaurants, spas, or conference halls, which add extra environmental impacts, making comparisons difficult. Only one product category is defined for this PEFCR. Creating sub-categories for hotel accommodation would need to consider factors like location across the EU, climate differences, and service levels like star ratings, which would complicate things further. Even with significant effort, benchmarks might not be fully reliable due to variations in location, equipment, and regional climate affecting energy use.

Please note: this content refers to the 1st draft PEFCR and it may be subject to review and update during the next steps of the project.

Hotels will be able to use the results of PEF studies carried out using this PEFCR for comparisons with their own performance at different times (i.e. for measuring potential improvements in the environmental performance over time). In addition, hotels may compare their service to other hotels. Guests will be able to compare the environmental performance among rooms/room types in the same hotel and among different hotels, particularly in the same location/region.

Specific conditions for comparisons performed by guest or hotel operators may be defined and included in the PEFCR, based on the feedback collected in the stakeholder consultations, the review by the review panel and the supporting studies.

The results obtained by applying this PEFCR cannot be used for comparative assertions with the benchmark. The benchmark included in a PEFCR is a measure of the average product (in this case service) sold in the EU. The benchmark defined in this PEFCR is a representation of an approximated average hotel room accommodation service, based on a small sample of real hotels located in different European climate regions and belonging to different market segments. 

In addition, the use of such a benchmark for comparison with specific PEF results of an individual hotel room would not be meaningful, since a single benchmark representing an ‘average’ EU accommodation service may for example misleadingly categorize most Nordic hotels as “below benchmark” and Southern European ones with lower energy demand as “better than benchmark” due to the hotel location, preventing fair and meaningful comparisons. 

Please note: this content refers to the 1st draft PEFCR and it may be subject to review and update during the next steps of the project.

A standardised methodological reference reduces complexity and costs, which is particularly beneficial for small and medium-sized enterprises (SMEs).

The PEFCR Hotel Accommodation Project Consortium is committed to addressing the needs of SMEs and integrating them throughout the process, with a focus on inclusive communication. Consequently, some members of our Technical Secretariat (TS) are SMEs.

The development of digital tools is not foreseen under this project. However, the PEFCR, once finalised, will be available to the sector and third parties as basis to implement such tools that would substantially further reduce costs and the LCA/EF expertise needed to calculate PEF study results.

Yes, hotels with good in-house Life-Cycle-Assessment-expertise and adequate capacities can independently conduct their PEF study. Smaller hotels or those without the necessary expertise can hire a PEF consultant to assist with the modelling and to guide them through the process. One has to expect a couple of expert working days (per hotel, not per room type), assuming an LCA/PEF software tool is available with the hotel accommodation model is pre-set and including a PEF report generator function, and the hotel setting is not overly complex. The inhouse-effort to compile the needed data of consumables and installed furniture, bedding materials etc. mostly in the room is to be considered as well. An external verification of the study is required; as established by the PEF method (see question 20).

The costs of conducting a PEF study vary significantly based on factors such as the hotel’s size, complexity, data-readiness at the hotel, and whether external consultants are needed. Similar costs are anticipated as for Environmental Product Declarations (EPDs) that have been established widely across construction industry and interior products. As digital tools for PEF studies become more accessible, the process becomes simpler and more cost-efficient and enables more hotels to conduct the study largely or fully independently.

For internal purposes and evaluations, third-party verification is not necessary, allowing companies to manage the studies fully internally, if wished so. However, for external communications, third-party verification is required in accordance with the PEF method. The costs for an external review of a PEF study can vary, influenced by the hotel's complexity and specific requirements outlined in the PEFCR, particularly whether the review is remote or on-site. Generally, the costs are similar to those for Environmental Product Declarations (EPD) reviews of complex products, i.e. a few to several person-days per hotel. This may extend somewhat for more complex hotel settings, low quality PEF studies (with extra loops for improvement and re-checks), use of not pre-reviewed PEFCR hotel accommodation models, and lack of review-process supporting tools or reporting requirements. 

The PEF complements, but does not replace, existing tools such as the EU Ecolabel (EPLCA 2020). There are already EU tools that could support the sustainability of the tourism sector: 

EMAS – the EU Eco-Management and Audit Scheme: it is a premium management instrument to evaluate, report, and improve organisations’ environmental performance. It is a systematic approach to environmental management for organisations to enhance their environmental performance, save energy, and optimise resource usage, through life cycle thinking.

The EU Ecolabel – is the EU Official label of environmental excellence, awarded to best in class products and services in the EU market. It can be awarded to best in class in terms of environmental performance and high-quality goods/services produced/offered globally and placed on the EU market that comply with specific criteria set for specific product groups. The EU Ecolabel criteria for tourism accommodation will most likely be revised soon. It is expected that the PEFCR for hotel accommodation will be considered in this revision.

The Product Environmental Footprint method, is the environmental accounting method recommended by the Commission to measure and communicate the environmental performance of the product (goods and services). The PEF method covers the full life-cycle of products.

Integrating the Product Environmental Footprint (PEF) method into a hotel's existing sustainability strategies offers a structured approach to calculation, communicating and importantly enhancing environmental performance. By adhering to the PEFCR requirements, hotels can benefit from comprehensive data collection that provides a clear understanding of the environmental impacts across various aspects of their operations, and use the data also in other applications. In doing so, hotel accommodation providers can make the data basis of their sustainability strategy even more robust. The PEF method helps identify and quantify key areas such as energy use, water consumption, and waste, but also key in-room products and e.g. cleaning/washing services that freqently require attention. The insights gained from this process are invaluable for continuous improvement, allowing hotels to refine their sustainability practices over time.

Moreover, using the PEF method facilitates effective communication of a hotel's environmental efforts. As a method recognized by the European Commission (see above, particularly in the context of substantiating green claims (adopted Directive on Empowering consumers for the Green Transition and upcoming Green Claims Directive), it provides credibility and transparency. This recognition enhances the hotel's reputation and trustworthiness among stakeholders, including guests and partners, by demonstrating a committed and scientifically grounded approach to sustainability. With these steps, hotels can seamlessly integrate the PEF method into their sustainability efforts, ensuring impactful and ongoing improvements.

Examples of environmental footprint results communication can be found for instance in a Report by the Joint Research Centre (JRC 2022: p. 22ff). Here you can see a PEF-score based factsheet for a product. 

Hotels can communicate the results of their Product Environmental Footprint (PEF) assessments through various channels to inform guests and stakeholders about their environmental performance. By utilizing communication channels, such as social media channels or the hotels website, hotels can effectively convey their PEF results and demonstrate their commitment to environmental sustainability to guests, employees, and stakeholders (European Commission 2021b). The information has to be compliant with the requirements of the Unfair Commercial Practices. The communication vehicle should comply with the principles of transparency, availability and accessibility, reliability, completeness, comparability and clarity, as described in the Commission Communication on Building the Single Market for Green Products. The final PEFCR on hotel accommodation may also set specific communication requirements.

The Product Environmental Footprint (PEF) is a Life Cycle Assessment (LCA)-based methodology for comprehensively assessing and communicating the potential environmental impacts throughout the life cycle of products, whether they are goods or services. The PEF uses existing methodologies and international standards to enhance the reproducibility and comparability of results across the entire value chain. This approach enables informed decision-making to reduce environmental footprints (EPLCA 2018 & European Commission 2021c).

Product Environmental Footprint Category Rules (PEFCR) are specific rules tailored to different product categories and based on the entire life cycle of a product or service, e.g. an overnight stay in a hotel. These rules add detail to the general guidelines for PEF studies by concentrating on key aspects and factors. PEFCRs aim to make study results more relevant, reproducible, and consistent (EPLCA 2018).

The Functional Unit (FU) defines the qualitative and quantitative aspects of the function(s) and/or service(s) provided by the product being evaluated. The functional unit definition answers the questions ‘what?', ‘how much?', ‘how well?', and ‘for how long?'  (European Commission 2021c).

The definition of the Representative Product (RP) is a crucial stage in developing the PEFCR. It represents the average product or service sold in the EU market within the product category under consideration. The environmental performance of the RP can serve as the knowledge basis for the development of the rules to be included in the PEFCR. The RP can also be used as a reference blueprint when applying the PEFCR, by customising the model to represent in the best possible way the actual product/service analysed. (EPLCA 2018 & European Commission 2021c).  A Representative Product (RP) does not have to be an actual product available for purchase instead it could be a virtual product, meaning it does not exist physically but is constructed using the average characteristics of all services or technologies present in the market.

The Technical Secretariat (TS) is the governing body that develops the PEFCR. It is a multi-stakeholder working group that meets periodically, representing at least 51 % of the EU hotel market. The TS prepares, maintains, and communicates all instructions related to the PEFCR development process according to specified rules and timelines. This includes drafting the PEFCR, collecting and analysing comments received and documenting how comments have been addressed. The TS is also required to appoint a chair, which oversees the various tasks of the TS and leads the physical consultation meetings (EPLCA 2018). 

In order to avoid negative rebound effects, it is essential to take a comprehensive view of decisions affecting the sustainability of policies, production systems, and services, encompassing the environmental, social, and economic dimensions inherent in sustainability. Life Cycle Assessment (LCA) is the practical application of this concept, aiming to comprehensively analyse the potential environmental impacts of decision-making processes. LCA serves as the scientific and methodological basis for the PEF. During the LCA all stages from raw material extraction to end-of-life are considered, as well as various environmental impact categories. LCA indicators are quantitative and based on mathematical models that describe the cause-effect relationships of different stressors. Therefore, due to its quantitative nature, LCA facilitates the selection of the best option among multiple scenarios. The analysis can be adapted to systems ranging from local to global scales, capturing the nuances of spatial variability. LCA methodology is standardised by ISO 14040 and ISO 14044, which detail the principles, application, study phases, requirements, critical review, and reporting. Other ISO standards in the 14040 series complement these guidelines, covering specific areas such as water footprint and eco-design, among others. (European Commission 2021c).

The Technical Advisory Board (TAB) on Environmental footprint was launched by the European Commission already during the pilot phase (2013 to 2017). This expert groups was renewed in 2024. The purpose of the TAB is to discuss and give advise to the Commission on  methodological issues related to the EF methods. Those interested in participating in the discussions must apply for membership via the register of Commission expert groups and similar bodies (europa.eu). The TAB expert group  is not involved in the  development of the PEFCR for hotel accommodation services but does scrutinize the final PEFCR draft and issue a positive or negative option on its endorsement.  (European Commission 2024).