EU Ecolabel, PEF and LCA for electronic products

Hugues Orgitello updated 7 Oct 2026 16 min read

An electronics manufacturer who wants to say something about the environmental performance of a product in the EU now works with four texts at once: the EU Ecolabel under Regulation (EC) 66/2010, a voluntary label whose only electronics criteria today cover displays; the Product Environmental Footprint (PEF) method of Commission Recommendation (EU) 2021/2279, a non-binding life cycle method that becomes binding only where a legal act calls on it; the ISO life cycle standards, ISO 14040 and ISO 14044, with ISO 14025 revised in 2026 for environmental product declarations (EPD); and, since 27 September 2026, the green claim bans of Directive (EU) 2024/825. The Green Claims Directive that was supposed to make PEF the reference for every claim is blocked. This guide reads each text as it stands on 7 October 2026, gives the article, the threshold and the date for each point, and lists the claims about these instruments that the texts contradict, including some that earlier versions of this page made.

What changed between 2024 and 2026

Date	Event	Source
28 February 2024	Directive (EU) 2024/825 adopted (published 6 March 2024)	OJ L, 2024/825
12 March 2024	Parliament first-reading position on the Green Claims proposal	European Parliament
17 June 2024	Council general approach on the Green Claims proposal	Council
18 July 2024	ESPR, Regulation (EU) 2024/1781, enters into force	ESPR Article 80
20 June 2025	Commission announces its intention to withdraw the Green Claims proposal; the 23 June 2025 negotiation meeting with Parliament and Council is cancelled	European Parliament legislative train
21 October 2025	2026 Commission Work Programme lists the Green Claims proposal as pending	European Parliament legislative train
27 March 2026	Deadline for Member States to transpose Directive 2024/825	Directive 2024/825, Article 4(1)
2026	ISO 14024 and ISO 14021 published in new editions, and ISO 14025:2026 in June, under the series title "Environmental statements and programmes for products"	ISO
1 June 2026	US Department of Energy becomes lead agency for Energy Star	Energy Star transition plan
27 September 2026	Directive 2024/825 applies	Directive 2024/825, Article 4(1)
31 December 2028	End of validity of the EU Ecolabel criteria for electronic displays	Decision (EU) 2020/1804, Article 4

Three kinds of environmental statement

The ISO 14020 family has long sorted environmental statements into three kinds. The vocabulary of "Type I" survives in EU law: Regulation 66/2010 and Directive 2024/825 both refer to "EN ISO 14024 type I" ecolabels.

Kind	Standard	Nature	Verification
Ecolabel ("Type I")	ISO 14024	Multi-criteria label, pass or fail	Third party, run by an ecolabelling programme
Self-declared claim ("Type II")	ISO 14021	Claim made by the manufacturer, often single-attribute	No third-party certification required by the standard
Environmental product declaration ("Type III")	ISO 14025	Quantified LCA-based declaration, no pass or fail	Independent verification within an EPD programme

ISO 14025:2026 drops the Type I, II, III classification language and defines EPDs as independently verified, LCA-based environmental statements, according to the International EPD System, a programme operator. The 2026 editions of ISO 14021 and ISO 14024 carry the new series title.

PEF is not a label. It is a calculation method that can feed an EPD, a claim or, where a legal act says so, a regulatory requirement.

EU Ecolabel: what Regulation (EC) 66/2010 says

Regulation 66/2010 replaced Regulation (EC) 1980/2000 (Article 18). The table follows the articles a manufacturer actually meets.

Provision	What it says
Article 1(2)	The Regulation does not apply to medicinal products or to any type of medical device
Article 6(3)	Criteria are based on the most significant environmental impacts over the whole life cycle, including climate change, resource use, hazardous substances, durability and reusability
Article 6(6)	The label may not be awarded to goods containing substances classified as toxic, hazardous to the environment or CMR under Regulation (EC) 1272/2008, or substances referred to in Article 57 of REACH, unless a derogation under Article 6(7) is granted in the criteria
Article 8(3)(c)	Each criteria Decision specifies its own period of validity
Article 9(1)	Where to apply: a product originating in one Member State goes to a competent body of that Member State; a product originating outside the EU goes to a competent body of any Member State where it is or will be placed on the market
Article 9(5)	The competent body checks completeness within two months and may reject the application if the file is not completed within six months of its notification
Article 9(8) and 9(9)	The label is used only after a contract based on the Annex IV template; the registration number is placed on the product
Article 9(13)	The label cannot be used as a component of a trademark
Annex I, Part A	Criteria correspond indicatively to the best 10 to 20 % of products on the EU market in environmental performance at the time of adoption

Fees (Annex III, as replaced by Regulation (EU) 782/2013)

Fee	Cap
Application fee	EUR 200 minimum, EUR 2 000 maximum
Application fee, SMEs and operators in developing countries	EUR 600 maximum
Application fee, micro-enterprises	EUR 350 maximum
Reduction for EMAS registration / ISO 14001 certification	30 % / 15 %, not cumulative
Annual fee	Flat fee, or at most 0.15 % of the annual EU sales value of the labelled product (ex-factory price for goods), capped at EUR 25 000 per product group per applicant
Annual fee, SMEs, micro-enterprises and applicants from developing countries	Reduced by at least 25 %
Inspection fee	May be charged by the competent body

The fees do not cover testing, third-party verification or on-site inspections, which the applicant pays separately. Each competent body sets its actual fees within these caps.

Electronic product groups

Product group	Decision	Status on 7 October 2026
Electronic displays (televisions, monitors, digital signage displays)	Decision (EU) 2020/1804 of 27 November 2020, product group code 022	In force, valid until 31 December 2028 (Article 4)
Personal, notebook and tablet computers	Decision (EU) 2016/1371	Valid for three years from adoption; end of validity 10 August 2019. No replacement Decision found on EUR-Lex

The JRC European Product Bureau lists finalised EU Green Public Procurement criteria for computers and for imaging equipment, which are a different instrument: they guide public buyers and do not give a right to use the EU Ecolabel logo. For other electronics, manufacturers use other ISO 14024 labels such as TCO Certified, Blue Angel or the Nordic Swan, each with its own criteria.

Electronic displays: the criteria in Decision (EU) 2020/1804

Criterion	Requirement (summary of the Annex)
1.1 Energy savings	After 31 March 2021, one of the top two energy classes with registered models in EPREL for that resolution and display type, rechecked at least every two years during the licence; on-mode power in normal configuration at most 64 W (125 W for digital signage displays of UHD resolution and above)
1.2 Power management	Manual brightness control; automatic brightness control meeting the 10 % reduction conditions of Regulation (EU) 2019/2021; quick start returning to standby or off at most 2 hours after the last user activity
2.1 Restricted substances	Excluded or limited substances, with listed derogations
2.2 Fluorinated greenhouse gases	Information from LCD panel suppliers on F-GHG use, emission intensity and abatement
3 Reparability and guarantee	Screen assembly and LED backlight, stands and power and control boards exchangeable with commercially available tools; no heat or chemical adhesives on the back cover; public repair manual; spare parts available for at least 8 years after end of production; commercial guarantee of at least 3 years at no extra cost
4.1 Recyclability	Plastic parts above 25 g of a single recyclable polymer or blend and marked per ISO 11469 and ISO 1043; at least 10 % post-consumer recycled plastic on average (excluding printed wiring boards)
4.2 Dismantling	Design for dismantling and recycling
5.1 and 5.2 Social criteria	Labour conditions audited against fundamental ILO conventions; sourcing of conflict-free minerals
6 Information	User information and the text on the EU Ecolabel

There is no packaging criterion and no take-back criterion in this Decision; take-back stays a legal obligation under the WEEE Directive 2012/19/EU. For the energy class side, see the ErP and ecodesign for energy efficiency guide.

Product Environmental Footprint (PEF)

Legal status

Recommendation (EU) 2021/2279 replaced Recommendation 2013/179/EU. It recommends that Member States, companies, schemes and the financial community use the PEF and OEF methods, and asks that PEF studies disclosed to third parties be verified. Its scope paragraph is explicit: it "does not apply to the implementation of EU mandatory legislation that foresees a specific methodology", though legislation may refer to it. The pilot phase from 2013 to 2018 produced 19 PEFCR and 2 OEFSR documents.

PEF therefore binds a manufacturer only through another act. Under ESPR, Article 2(24) of Regulation (EU) 2024/1781 defines the environmental footprint as a quantification "based on the Product Environmental Footprint method established by Recommendation (EU) 2021/2279 or other scientific methods", and the calculation rules come with each delegated act. See the ESPR guide and the DPP guide on the Digital Product Passport.

Two conditions for any PEF study

Section 2.2 of Annex I sets two requirements before anything else: the bill of materials shall be specific to the product in scope, and the modelling of the manufacturing processes shall be based on company-specific data. A study built only on generic datasets is not a PEF study.

PEFCR documents and electronics

A PEFCR fixes, for one product category, what Annex I leaves open: functional unit, system boundary, default scenarios, data requirements, benchmark. Where a PEFCR exists, the Recommendation says it should be used. The Commission PEF method page lists:

Status	PEFCR documents
New, completed	Apparel and footwear; cut flowers and potted plants; synthetic turf
New, in development	Aviation, drones and eVTOLs; marine fish; space; tourism
In revision	Feed for food-producing animals; batteries and accumulators; beer; pasta; pet food; dairy products

The same page states that category rules not on the list "are either outdated or are private initiatives". The pilot-phase PEFCR documents for IT equipment (storage) and uninterruptible power supplies are not on it. For an electronic product, the only current Commission PEFCR work is the one on batteries and accumulators; everything else is a PEF study under Annex I without category rules, or an ISO 14040 / 14044 LCA.

The sixteen EF impact categories (Annex I, Table 2)

All sixteen shall be applied, without exclusion. Climate change is reported as a total; the fossil, biogenic and land-use sub-indicators are reported separately when each contributes more than 5 % of the total.

EF impact category	Unit	Characterisation model	Robustness
Climate change, total	kg CO2 eq	Bern model, GWP over 100 years (IPCC 2013)	I
Ozone depletion	kg CFC-11 eq	EDIP model on WMO ozone depletion potentials (WMO 2014 + integrations)	I
Human toxicity, cancer	Comparative toxic unit for humans	USEtox 2.1 (Fantke et al. 2017), adapted by the JRC	III
Human toxicity, non-cancer	Comparative toxic unit for humans	USEtox 2.1, adapted by the JRC	III
Particulate matter	Disease incidence	PM model (Fantke et al. 2016 in UNEP 2016)	I
Ionising radiation, human health	kBq U235 eq	Human health effect model (Frischknecht et al. 2000)	II
Photochemical ozone formation, human health	kg NMVOC eq	LOTOS-EUROS model as applied in ReCiPe 2008	II
Acidification	mol H+ eq	Accumulated exceedance (Seppälä et al. 2006, Posch et al. 2008)	II
Eutrophication, terrestrial	mol N eq	Accumulated exceedance (Seppälä et al. 2006, Posch et al. 2008)	II
Eutrophication, freshwater	kg P eq	EUTREND model as applied in ReCiPe	II
Eutrophication, marine	kg N eq	EUTREND model as applied in ReCiPe	II
Ecotoxicity, freshwater	Comparative toxic unit for ecosystems	USEtox 2.1, adapted by the JRC	III
Land use	Dimensionless (pt)	Soil quality index based on the LANCA model, CF version 2.5	III
Water use	m3 water eq of deprived water	AWARE model (UNEP 2016)	III
Resource use, minerals and metals	kg Sb eq	Abiotic depletion, ultimate reserves, as in CML 2002 v4.8	III
Resource use, fossils	MJ	Abiotic depletion, fossil fuels, as in CML 2002 v4.8	III

Life cycle stages (Annex I, section 4.2)

The default stages are: raw material acquisition and pre-processing (including production of parts and components), manufacturing, distribution (including storage), use, and end of life (including recovery or recycling). Stages may be split or added with a justification. For intermediate products, distribution, use and end of life are excluded.

Normalisation and weighting (Annex I, section 5.2)

Weighting is "a mandatory step in PEF studies". Normalised results are multiplied by the EF weighting factors, published online by the JRC rather than in the Recommendation, and may be aggregated into a single overall score in points. Normalised results shall not be aggregated without weighting, and the characterised and normalised results shall be reported alongside the weighted results. The most relevant impact categories are those that together contribute at least 80 % of the single overall score (section 6.3).

ISO life cycle standards

Standard	Current edition	Role
ISO 14040	2006, with Amd 1:2020	Principles and framework of LCA
ISO 14044	2006, with Amd 1:2017 and Amd 2:2020	Requirements and guidelines: goal and scope, inventory, impact assessment, interpretation
ISO 14025	2026 (replaces 2006)	Environmental product declarations and EPD programmes
ISO 14024	2026	Ecolabels (formerly "Type I")
ISO 14067	2018	Carbon footprint of products

A PEF study is an LCA in the sense of ISO 14040 / 14044 with prescriptive choices added: the impact categories and models of Table 2, mandatory weighting, company-specific data for manufacturing. Annex I uses the term "EF impact category" in place of the "impact category" of EN ISO 14044:2006. An ISO 14044 LCA that does not make those choices can be valid, but it is not a PEF study.

An EPD is published by a programme operator (for example the International EPD System, IBU in Germany or INIES in France for construction products) under Product Category Rules (PCR) and is independently verified. It discloses results without a pass or fail threshold.

Green claims: what applies, what is blocked

Directive (EU) 2024/825, applying from 27 September 2026

The Directive amends the Unfair Commercial Practices Directive 2005/29/EC (UCPD) and Directive 2011/83/EU. The Annex I blacklist of the UCPD gains, among others:

UCPD Annex I point	Practice banned in all circumstances
2a	Displaying a sustainability label that is not based on a certification scheme or not established by public authorities
4a	Making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance relevant to the claim
4b	Making an environmental claim about the entire product when it concerns only a certain aspect of it
4c	Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact in terms of greenhouse gas emissions

"Recognised excellent environmental performance" means performance compliant with Regulation (EC) 66/2010, with officially recognised national or regional EN ISO 14024 ecolabels, or top performance under other Union law; recital 10 cites class A under the energy labelling Regulation (EU) 2017/1369 as an example. A "certification scheme" needs third-party monitoring by a party independent of both the scheme owner and the trader. Recital 9 lists "energy efficient" among the generic claims. Claims about future environmental performance need a detailed and realistic implementation plan with measurable, time-bound targets, regularly verified by an independent third-party expert whose findings are made available to consumers (new Article 6(2)(d) UCPD).

The Green Claims Directive proposal

The proposal COM(2023) 166 of 22 March 2023 would have required explicit environmental claims to be substantiated and verified before use. It did not impose PEF: recital 32 says that PEFCR and OEFSR category rules "can be used to support the substantiation of claims", and the Commission would have been empowered to adopt product-specific rules by delegated act. After the Commission announced on 20 June 2025 that it intended to withdraw the proposal, the negotiation meeting of 23 June 2025 was cancelled; the 2026 Work Programme lists it as pending, and the Parliament legislative train shows it as blocked on 20 September 2026. Nothing in it applies to products today.

Which instrument for which purpose

Instrument	Binding?	Output	Typical use for an electronic product
EU Ecolabel	Voluntary; once awarded, also proves recognised excellent environmental performance under Directive 2024/825	Logo and registration number on the product	Displays sold to consumers or public buyers
PEF study	Voluntary unless a legal act refers to it	Report with sixteen characterised, normalised and weighted results	Supporting a claim, preparing for ESPR footprint information
EPD (ISO 14025)	Voluntary	Verified public declaration within a programme	B2B tenders, data centre and integrator requests
Self-declared claim (ISO 14021)	Voluntary, but subject to the UCPD bans from 27 September 2026	Text or symbol	Specific, substantiated single-attribute claims only

Other ecolabels and Energy Star

Label	Operator	Note
TCO Certified	TCO Development (Sweden)	ISO 14024 label for IT products and displays
Blue Angel	German federal government	National ecolabel of Germany
Nordic Swan	Nordic Ecolabelling	Official ecolabel of the Nordic countries
Energy Star	US EPA and US Department of Energy (DOE lead agency since 1 June 2026)	Energy efficiency only, not a life cycle label

Whether a private ISO 14024 scheme counts as "officially recognised" in a Member State for point 4a of the UCPD blacklist is a question for each national authority; the Directive does not list schemes.

The EU and the US ran a joint Energy Star programme for all office equipment, not only displays and printers. The last agreement, concluded by Council Decision 2013/107/EU for five years, expired on 20 February 2018 and was not renewed. A Memorandum of Agreement signed on 3 March 2026 made DOE the lead agency from 1 June 2026. See the Energy Star programme guide and the EU and US dual certification guide.

Claims the texts contradict

Claim	What the text says
"The Green Claims Directive is expected to be adopted in 2025-2026 and makes PEF the default method"	The Commission announced its intention to withdraw it on 20 June 2025; the file is blocked. The proposal only said that PEF category rules "can be used to support" substantiation.
"PEF is becoming binding through the Green Claims Directive"	PEF is a recommendation. It binds only where an act refers to it, as ESPR Article 2(24) does for the environmental footprint, with or without other scientific methods.
"Two electronic groups have active EU Ecolabel criteria" (this page, earlier)	Only electronic displays. The computers criteria of Decision 2016/1371 ended on 10 August 2019.
"The applicant chooses any Member State competent body"	Article 9(1): a product made in one Member State goes to that Member State; only products from outside the EU, or made in several Member States, give a choice.
"A licence typically runs three years; criteria are generally valid six years"	Neither figure is in the Regulation. Each Decision sets its validity (31 December 2028 for displays; three years for computers).
"Typical EU Ecolabel criteria for electronics include packaging and take-back"	Decision 2020/1804 has neither; it has energy, substances, F-GHG, reparability with 8-year spare parts and a 3-year guarantee, recyclability, social criteria and information.
"A PEFCR exists for IT equipment storage, so a storage product can use it"	The Commission list no longer includes it; category rules not on the list are outdated or private.
"PEF requires primary data for the top three hotspot processes"	Annex I section 2.2 requires a product-specific bill of materials and company-specific data for manufacturing.
"The PEF single score is optional"	Weighting is a mandatory step; characterised and normalised results are reported alongside.
"The EU-US Energy Star agreement expired in 2018 for displays and printers; EPA runs Energy Star" (this page, earlier)	The agreement covered office equipment and expired on 20 February 2018; DOE has been lead agency since 1 June 2026.
"The Construction Products Regulation makes ISO 14025 EPDs mandatory" (this page, earlier)	Not a point we could source for this page; it was removed.
"ISO 14025:2006 is the current EPD standard"	ISO 14025:2026 replaced it in 2026.

Practical steps for an electronics design office

1. Check the green claims you already make. From 27 September 2026, "eco-friendly", "green" or "energy efficient" without recognised excellent environmental performance, and "carbon neutral" based on offsets, are banned in consumer communication. Recognised excellent performance means the EU Ecolabel, an officially recognised EN ISO 14024 label, or top performance under Union law such as energy class A.
2. Confirm whether a criteria set exists. For a display, Decision 2020/1804 applies until 31 December 2028; plan the energy class, the 8-year spare parts commitment and the 3-year guarantee early. For other electronics there is no EU Ecolabel route today.
3. Collect company-specific data for manufacturing. A PEF study, and very likely any future ESPR footprint requirement, needs a product-specific bill of materials and measured manufacturing data. Write the data request into supplier contracts.
4. Pick the vehicle. Consumer display: EU Ecolabel or another ISO 14024 label. Professional equipment: an EPD under ISO 14025:2026 in an established programme. Internal eco-design: an ISO 14044 LCA or a PEF study, published or not. Track the ESPR working plan in the ESPR guide for the act that may set the method for your product group.

Substance limits that criteria build on come from RoHS Directive 2011/65/EU and REACH; see the REACH guide. For security requirements that ESPR and the Cyber Resilience Act may both touch through software updates, see that guide; for end of life, the WEEE guide. Terms (PEF, PEFCR, EPD, PCR, LCA) are in the spilma glossary.

See also

• Conflict minerals: Dodd-Frank, EU 2017/821, CMRT and EMRT
• IEC 62133 and UN 38.3: Li-ion battery safety and transport
• Lithium battery shipping: IATA DGR, IMDG, ADR, DOT
• RoHS 2011/65/EU: restricted hazardous substances in EEE
• EU Battery Regulation 2023/1542

Working on PEF, EPD and EU Ecolabel scoping for an electronic product for a real product? AESTECHNO can audit your design and certification plan. Get in touch

Sources & references

1. Regulation (EC) 66/2010 on the EU Ecolabel, EUR-Lex eur-lex.europa.eu/eli/reg/2010/66/oj
2. Commission Regulation (EU) 782/2013 replacing Annex III (fees) to Regulation (EC) 66/2010, EUR-Lex eur-lex.europa.eu/eli/reg/2013/782/oj
3. Commission Decision (EU) 2020/1804 establishing EU Ecolabel criteria for electronic displays, EUR-Lex eur-lex.europa.eu/eli/dec/2020/1804/oj
4. Commission Decision (EU) 2016/1371 establishing EU Ecolabel criteria for personal, notebook and tablet computers (end of validity 10 August 2019), EUR-Lex eur-lex.europa.eu/eli/dec/2016/1371/oj
5. Product groups, European Product Bureau, European Commission, Joint Research Centre susproc.jrc.ec.europa.eu/product-bureau/product-groups
6. Commission Recommendation (EU) 2021/2279 on the use of the Environmental Footprint methods, EUR-Lex eur-lex.europa.eu/eli/reco/2021/2279/oj
7. PEF method: category rules completed, in development and in revision, European Commission green-forum.ec.europa.eu/green-business/environmental-footprint-methods/pef-method_en
8. Directive (EU) 2024/825 on empowering consumers for the green transition, EUR-Lex eur-lex.europa.eu/eli/dir/2024/825/oj
9. COM(2023) 166, proposal for a Directive on substantiation and communication of explicit environmental claims (Green Claims Directive), EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023PC0166
10. Legislative train: Substantiating green claims, European Parliament www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-substantiating-green-claims
11. Regulation (EU) 2024/1781 (ESPR), Article 2(24) environmental footprint, EUR-Lex eur-lex.europa.eu/eli/reg/2024/1781/oj
12. ISO 14040:2006, Life cycle assessment, Principles and framework, ISO www.iso.org/standard/37456.html
13. ISO 14044:2006, Life cycle assessment, Requirements and guidelines (Amd 1:2017, Amd 2:2020), ISO www.iso.org/standard/38498.html
14. ISO 14025:2026, Environmental statements and programmes for products, Environmental product declarations (EPDs), ISO www.iso.org/standard/14025
15. ISO 14025:2026 is published (programme operator news, secondary source), International EPD System www.environdec.com/news/iso-140252026-is-published
16. ISO 14024:2026, Environmental statements and programmes for products, Ecolabels, ISO www.iso.org/standard/14024
17. ISO 14067:2018, Greenhouse gases, Carbon footprint of products, ISO www.iso.org/standard/71206.html
18. Council Decision 2013/107/EU on the EU-US agreement on energy-efficiency labelling of office equipment, EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32013D0107
19. ENERGY STAR Transition Plan (August 28, 2026), ENERGY STAR (EPA and DOE) www.energystar.gov/sites/default/files/2026-08/ENERGY%20STAR%20Transition%20Plan%20Final%2008.28.2026_508.pdf