- 1The ESPR is a framework regulation: indicators, thresholds, the method and DPP content all go through the category's delegated act.
- 2PEF is the method cited by the ESPR ("or other scientific methods", Article 2, point 24). It is never mandatory in its own right.
- 3Neither the ESPR nor its DPP annex mentions ISO 14040/14044. An ISO LCA has no legal status of its own within the DPP framework.
- 4Three useful actions before the delegated act: structure primary data (reusable everywhere), model using PEF when a PEFCR exists and document choices for auditability.
1The ESPR sets no method: it refers to delegated acts
The ESPR eco-design regulation is a framework text. Its Article 4(1) empowers the Commission to adopt delegated acts supplementing the regulation "by establishing ecodesign requirements". The ESPR itself therefore contains no requirement directly applicable to a product. Neither indicators nor thresholds, neither the content of the digital product passport (DPP) nor the environmental calculation method.
Who decides a DPP's calculation method?
Three levels, only one matters for your calculation: your category's delegated act. The framework regulation names PEF without requiring it; CEN standards standardise the technical plumbing. The method itself sits at the middle level.
Annex I confirms the mechanism. It lists "the environmental footprint of the product" as a possible parameter, but always "in accordance with the applicable delegated act". Article 9(2), which governs the DPP, also leaves the delegated act to specify passport data. The framework regulation sets out no cross-cutting method.
Three levels of legal texts overlap, and only one sets the method applicable to a product. The ESPR regulation sets the vocabulary and the DPP requirement. Each category's delegated act sets the method, indicators and passport content. The CEN JTC 24 harmonised standards (cited in the OJEU in July 2026: EN 18216, 18219, 18220, 18221, 18222, 18223) standardise the technical plumbing: exchange protocols, identifiers, APIs. CEN-CENELEC describes them as "transverse and product agnostic": they say nothing about the calculation method. No general DPP method exists or is planned.
2PEF is the reference cited by the ESPR, rather than a requirement
Article 2, point 24 of the ESPR defines the environmental footprint as "a quantification of the environmental impacts resulting from a product throughout its life cycle ...] based on the product environmental footprint method established by Recommendation (EU) 2021/2279 or other scientific methods developed by international organisations, widely tested in collaboration with different industry sectors and adopted or implemented by the Commission in other provisions of Union law". [PEF is the method cited by the text, which nevertheless leaves the door open to "other scientific methods".
PEF sits within Recommendation (EU) 2021/2279 of 15 December 2021. However, Article 288 TFEU states: "recommendations and opinions shall have no binding force". PEF as such is never mandatory in its own right. Its own point 1.3 establishes this subordination: "This Recommendation may however be referred to by Union legislation or policy as a method for the calculation". This is precisely the mechanism used by the Batteries Regulation (EU) 2023/1542, which makes PEF legally binding for this sector alone.
Recital 23 of the ESPR sets out the trajectory: the Commission "should take into account" the PEF method in future delegated acts. The verb remains flexible: "should", rather than "must". PEF is a de facto standard for EU environmental data, very likely the foundation of future delegated acts. Yet no legal text makes it a de jure standard for all DPPs.
3PEF or ISO 14040 LCA: what changes in practice
A point often overlooked in general-interest analyses: neither the ESPR nor its Annex III (DPP content) mentions ISO 14040 and ISO 14044. An ISO LCA has no legal status of its own within the DPP framework. A future delegated act may recognise it under Article 39 ("reliable, accurate and reproducible procedures") or a future harmonised standard. No legal text guarantees this as of 20 July 2026.
PEF or ISO LCA: where the real differences lie
Six defining dimensions for a manufacturer equipped for ISO LCA wondering what moving to PEF would involve. These are not two dialects of the same language: they are two different evidence regimes.
For a manufacturer already equipped for ISO LCA, the question becomes: what does moving to PEF involve in practice? Six differences separate the two frameworks.
The weighted single score, central to PEF (and Ecobalyse), is precisely what ISO 14044, section 4.4.5 prohibits publishing in public comparisons. The two frameworks constitute distinct evidence regimes. PEF in principle requires EF datasets (the Commission's Life Cycle Data Network), rather than ecoinvent. As these datasets are currently scarce, the transition guidance published by the Commission in July 2026 nevertheless permits other datasets, outside PEFCRs and for the 2025-2028 period, subject to conditions and with a comparability warning. An LCA carried out using ecoinvent must therefore be remodelled with EF datasets, or documented under this guidance, to claim PEF compliance, and differences in results for the same processes can be significant (characterisation factors, allocations and system boundaries differ between the two databases).
In terms of tools, the market is divided between two families. Specialist LCA software (SimaPro, openLCA, Sphera LCA for Experts, formerly GaBi, Umberto) allows full modelling and all incorporate the EF 3.1 method and EF datasets. Automated LCA SaaS platforms (Glimpact for native PEF modelling, Sweep or Carbonfact for carbon footprints at scale) offer guided modelling with preconfigured datasets, suited to high-volume product calculations or environmental labelling needs. No official software certification exists, either for PEF or for the DPP. Compliance is assessed at study level, rather than tool level.
4Where to start before the delegated act
Between 2026 and 2028, most manufacturers are in an interim period. No methodological requirement for their category outside batteries and buildings, but a calculation to redo if they take the wrong direction. The infographic below summarises the actions that protect your calculation and the mistakes that force you to start again.
Prepare your DPP without having to start again
Between 2026 and 2028, most manufacturers are in an interim period: no required method, but a calculation to redo if they take the wrong direction. On the left, the actions that survive any scenario; below, the errors that force you to start again.
Structuring primary data (energy mix by site, transport, processes, tier 2 and 3 suppliers) is the investment that remains useful whatever methodological choice is made. Whether your category's delegated act ultimately requires strict PEF, an adapted sector-specific PEFCR, a method recognised under Article 39 or a new harmonised standard: in every case, these data can be reused without being collected again. For more on operational preparation, see How much does an LCA cost? and Eco-design: where to start your first LCA. To organise the passport itself, our DPP support covers the data to gather, who holds them and their updates; the impact study is defined according to product needs.
5Key takeaways
No European legal text requires PEF for a DPP in general as of 20 July 2026. The ESPR sets no method: everything goes through the category's delegated act. Only one sector has its method anchored in a regulation: batteries, aligned with PEF by Annex II to Regulation 2023/1542, but the delegated act that must incorporate the JRC CFB-EV rules has still not been adopted. Construction is an exception with EN 15804 required by the CPR. For all other categories, no act has been adopted.
In practice. Structure primary data (the only data that remain useful whatever the scenario), model using PEF whenever a PEFCR exists for the category and document choices for auditability. Avoid: an in-house method that does not implement the EF 3.1 assessment method (still the reference for PEFCRs pending EF 4.0, even though EF-compliant datasets are currently scarce), a DPP platform mistaken for a calculator (it transports data rather than producing them), a single-indicator PCF when your category may have to report the 16 PEF indicators.
