Transitional guidance on the limited availability of EF-compliant datasets

The current availability of EF-compliant datasets is limited. To ensure that EF studies can still be carried out during this transitional period (2025-2028), the European Commission has issued guidance that permits the use of alternative datasets under specific conditions.

Data hierarchy

Follow the steps below whenever the Product Environmental Footprint (PEF) or Organisation Environmental Footprint (OEF) methods require the use of EF-compliant datasets and no valid Product Environmental Footprint Category Rules (PEFCR) or Organisation Environmental Footprint Sector Rules (OEFSR) are available.

Please note that this does not apply to studies conducted in accordance with a valid PEFCR or OEFSR. If PEFCR or OEFSR are available, users should follow the rules set out in Section 2.2 of this European Commission guidance document. Existing PEFCRs and OEFSRs remain valid until EF 4.0 is implemented.

Step 1: Use EF-compliant datasets

Use EF-compliant secondary datasets whenever they are available.

Step 2: Use ILCD-EL-compliant datasets

If no EF-compliant dataset is available, use datasets compliant with the International Reference Life Cycle Data System Entry Level (ILCD-EL). Source all these datasets from a single process-based database whenever possible. Where necessary, datasets from multiple databases may be combined. Their use must be documented in the EF report.

Step 3: Omit the process if no suitable dataset exists

If neither an EF-compliant nor an ILCD-EL-compliant dataset is available, the process should be omitted from the assessment. Clearly document this limitation in the EF report.

Required disclaimer

During this interim period, EF studies may still be considered EF-compliant even when non-EF-compliant datasets contribute more than 10% of the single overall score, provided that the following disclaimer is included:

‘This EF study was performed using non-EF-compliant datasets selected by the author, which may hinder comparability of results.’