
A summary of the discussion paper by Hemdrup & Thy, Bureau Veritas Solutions Denmark A/S
In their discussion paper “Closing the gap. The critical role of LCA methodology in decision making. A case of harmonisation between PEF and EPD”, authors Waldemar C. Hemdrup and Charlotte Thy analyse how inconsistencies in LCA methodology affect environmental communication and decision-making.
By comparing the structures and use cases of EPD (Environmental Product Declarations) and PEF (Product Environmental Footprint), they make the case for harmonisation.
Different frameworks, shared goal
While PEF and EPD were developed for different purposes; EPD primarily for B2B communication (especially within construction), and PEF for both B2B and B2C across sectors they ultimately aim to do the same:
Assess the environmental impact of products.
“(…) the EPD and PEF methodologies have different purposes – EPD is designed for B2B communication, while PEF can be used for both B2B and B2C (Durão, et al., 2020). EPD has been developed with construction products in mind, while PEF is intended for general products, with sector-specific PEFCR rules.”p. 40
However, the lack of harmonisation between them undermines that goal according to the authors.
The case for harmonisation
Although both frameworks rely on LCA standards like ISO 14040/44 and EN 15804, Hemdrup & Thy note that differences in scope, data sources, and allocation rules can lead to non-comparable results even for similar products.
“The harmonisation between different methodologies is essential to the green transition in the market, but it is not feasible to harmonise methodologies across platforms when there is no harmonisation within the same platform or framework. The lack of harmonisation within the EPD scheme has been known for more than a decade.”p. 22
EPD: Market recognition, but variability
EPDs are well-established in many industries and provide verified declarations of a product’s environmental impact. But the authors emphasise that the flexibility built into the system through varying PCRs (Product Category Rules) and programme operator rules often results in inconsistencies.
“(Konradsen, et al., 2024) present a paper where it was found that for three different product categories – insulation, flooring, and cladding – 3–12% of the EPDs are incomparable, even though they are following the same PCR.”p. 22
PEF: Structured, comparable and decision-ready
PEF, on the other hand, offers a more standardised and less flexible methodology, aimed at improving consistency and enabling comparison. With strict requirements on data sources, allocation, and full life-cycle coverage, PEF results are more suited for operational use e.g., product development and business strategy.
Synergy, not authority
The authors do not argue that one system should replace the other. Rather, they encourage alignment: combining EPD’s market credibility and verification with PEF’s methodological accuracy and comparability.
“Policymakers have a great responsibility to initiate dialogues with program owners of other LCA methodologies, such as EPD, to work towards harmonisation. LCA has transitioned from an industry-driven to a policy-driven approach, shifting the responsibility to policymakers.”
p. 39
Why it matters: Data must enable decisions
Without harmonisation, LCA data risks becoming unusable in practice despite the growing demand for transparency across regulatory initiatives in the EU such as Green Claims, CSRD, Ecodesign etc.
“The coexistence of PEF and EPD, without proper harmonisation, means the market and consumers are faced with incomparable environmental impact data, hindering their ability to make informed, sustainable choices. Addressing the disconnect between these methodologies should be a priority to ensure effective communication of environmental information and support the transition to a more sustainable economy.”
p. 40
Next steps: Align what we already have
The report concludes that instead of developing a new system from scratch, the logical next step is to align the methodologies already in use.
“Developing a single methodology that accurately assesses environmental impact across all sectors is extremely challenging. As such, harmonising the existing EPD approach with PEF may be a more practical solution. (…) The reason EPD needs to harmonise with PEF, rather than the other way around, is that the European Union is actively promoting the use of LCA and positioning PEF as the preferred methodology.”
p. 41
This paper makes a strong, well-documented case for LCA harmonisation as a precondition for real climate action. Hemdrup & Thy argue that alignment between PEF and EPD is not just possible, but necessary for enabling informed decisions, fair comparisons, and credible communication.
Looking ahead from a Målbar perspective: Building shared tools for a shared direction
As highlighted in the discussion paper, harmonising LCA methodologies is not just a technical exercise. It is a key enabler for climate-reflected design, procurement, and communication.
Through the project Climate Impact in the Furniture Industry – One Common Language, we have taken a significant step towards understanding and communicating how EPD and PEF each approach climate calculations – and what this means in practice for companies navigating both frameworks.
Rather than choosing between the two, our joint work with Aalborg University and Lifestyle & Design Cluster in Denmark has focused on creating clarity about why and how the methods differ, and on building a transparent conceptual guide that companies can use to communicate consistently about their climate footprints.
The outcome is a realistic and usable conceptual frame that supports dialogue and provides context for comparability, even in the absence of harmonised EU rules. It serves as a first step towards a shared language that can help the sector move forward with greater confidence and understanding until full regulatory alignment is in place.
“This project shows how essential dialogue and communication is in providing the much needed clarity in this very complex agenda. Until we can agree a harmonised method and set equal requirements in the market, it is this shared understanding and common language that is essential in our push towards transparent climate communication,” – Iben Garland Sonne, Head of Community Impact at Målbar.
Read more about the project (DA)
Source:
Hemdrup, W.C. & Thy, C. (2024). Closing the gap. The critical role of LCA methodology in decision making. A case of harmonisation between PEF and EPD. Bureau Veritas Solutions Denmark A/S.


