Summary

The words “environmental footprinting” are appearing more and more in a regulatory context, with mentions of the European Commission Product Environmental Footprint (PEF) methodology increasing in recent legislative proposals, and it feels like companies need to learn a whole new approach to simply comply with legislation.

But Environmental Footprinting is nothing new. It’s simply the overarching term for corporate footprinting or carbon footprinting. It’s the basis of the calculations done by all the companies that have set Science-Based Targets and shared their ambitious emission reduction plans for the last decade or so.

“We’ve all had to shift from storytelling to data. But now that data will be regulated, comparable — and potentially public.”

What’s at the core of environmental footprinting?

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How do corporate and product footprints interact?

Theoretically, the sum of the product footprint of your entire portfolio and the overheads (offices, commuting, etc.) should lead to your corporate footprint, meaning it’s important to make sure the data you’re using is consistent, reliable, and transparent, and that you approach footprinting holistically as a company.

Legislations concerning Enviromental Footprinting

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The Old Timer - CSDDD: Corporate Sustainability Reporting Directive (adopted, currently being simplified through the omnibus I proposal). Companies in scope will have to first identify sustainability topics which are material to them, and climate change is likely to be material for everyone as we’d be hard pressed to find an activity which isn’t impacted or impacting climate change in 2025! These companies then have to report their corporate footprint.

The Most Advanced - French Climate Law (Loi Climat, adopted). If a company wants to make a voluntary claim on the environmental performance of its products, it must use the French ecoscore, on its own or as a complement to their claim. A year after the implementation of the law, third parties will be empowered to calculate the footprint of products using public information.

The Most Ambitious - Ecodesign for Sustainable Product Regulation (Textile Delegated Act in negotiation). ESPR is a sector agnostic regulation which opens a lot of doors to help make sustainable products the norm in the EU. The textile sector is the first sector to be addressed, and all eyes are on the legislator to see which doors will remain open, and which will be closed. Environmental footprinting is on the list, and it could be used either as an information (to be disclosed to the public) or as a performance requirement (maximum footprint for example).

The Late Comer - Substantiating Green Claims directive ****(in negotiation). After over three years of discussions and pauses, the conversation on the SGC directive is extremely active in Q2 2025. The draft directive relies on environmental footprinting, and particularly the European Commission’s Product Environmental Footprint (PEF) method to substantiate complex environmental claims.

The Most Discreet - the ****Waste Framework Directive ****(in revision). The WFD aims to improve waste practices in the EU, for example through the mandatory set up of Extended Producer Responsibilities (EPR) fees, which will be eco-modulated and based on ESPR requirements, looping back environmental footprinting.

What Should you be doing?

Brands

Whether you’re aiming to comply with upcoming rules or gain a competitive edge, now’s the time to prepare for regulated environmental footprinting.

  1. Clarify your sustainability strategy - Do you want to heavily communicate about the sustainability or your products, or is that not a differentiator for your brand? This will make an important difference for step 2.
  2. Understand the legislative landscape – Learn what’s required and when based on your company needs. Voluntary claims are likely to be heavily regulated. If this is not a company priority, the legislative pressure will not be as overwhelming.
  3. Understand your product portfolio - At a high level, where is your impact expected to come from, and which part of your portfolio should you be focusing on? Do you know where to find the data you will need, like your bill of materials or details on your distribution channels?
  4. Engage your value chain – Begin dialogues with suppliers on data sharing — from energy use and water consumption to chemicals and transport.
  5. Select the right data partners – Based on sound policy understanding, work with LCA providers that align with standardised (EU or French) methodology.
  6. Improve your product portfolio – Use your environmental data to make better product development decisions before compliance deadlines hit.
  7. Plan for consumer disclosure – Prepare your teams for potential broader transparency requirements.

This can be overwhelming, but here’s what we recommend to get you started:

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