The Product Environmental Footprint method could become the EU’s guiding approach for environmental impact assessment; to be fit for purpose, it should appraise the carbon footprint of bio-based products. 

As the European Commission increasingly plans to rely on the Product Environmental Footprint (PEF) method as the guiding approach for environmental impact assessment, an accurate approach to assess the carbon footprint of bio-based products is critical.  

However, in the currently proposed PEF rules addressing biogenic carbon, there is no recognized benefit granted for the use of biogenic carbon at the beginning of the product life cycle. Thus, as it stands, there is no appropriate incentive to use bio-based resources. This is at odds with Europe’s ambitions for a climate-neutral future and needs to change. 

Current PEF rules fail to recognize the advantages of biogenic carbon 

Bio-based products are wholly or partly derived from renewable materials of biological origin, such as crops, trees, algae, biological waste, and residues. During the growth process, the plants remove CO2 from the atmosphere and through photosynthesis convert it into bi

omass, which then can be used for material production. By now, the bioeconomy has already become a part of people’s daily lives, with bio-based plastics, used in a wide range of applications and areas. 

Thanks to their properties, these products clearly contribute to the EU’s aim of shifting to a circular economy. They are suitable for a range of end-of-life options: re-use as well as recycling and upcycling. At the end of the cycle, if they are biodegradable under certain conditions, they can even be returned to natural processes, for example by means of industrial composting and the production of compost. 

However, despite the EU acknowledgement that bio-based products play a critical role in climate mitigation, the current PEF methodology does not recognize the environmental advantage of employing biogenic carbon at the beginning of the product’s life cycle over the use of fossil carbon. In other words, the methodology fails to incentivize the use of renewable materials of biological origin over fossil-based materials.  

Instead, the method foresees a CO2 burden at the end of the life cycle. But only for the incineration of fossil-based and not for biogenic carbon. Hence, this approach not only fails to properly allocate CO2 credits and burdens to the points in time in which they occur, it also breaches the principle of treating equal factors equally and different factors differently. The emission of greenhouse gases into the atmosphere must always be accounted for as a burden, irrespective of its source. The proposed methodology does not reflect the environmental challenges we are facing today. 

The benefits of clear, transparent and accurate accounting rules 

European Bioplastics, alongside eight European associations, jointly representing industries producing bio-based products, recently p