Environmental footprinting in Europe is entering a new phase.
In April 2026, the European Commission’s Environmental Footprint Technical Advisory Board (EF TAB) previewed a broad set of potential updates to the Environmental Footprint (EF) methodology the framework underpinning Product Environmental Footprint (PEF) calculations and many sustainability assessments across Europe.
While the review process is still ongoing and final decisions have not yet been adopted, the direction is becoming increasingly clear:
Environmental footprinting is evolving from relatively standardized carbon-focused reporting toward more granular, multi-impact, and verification-intensive environmental assessment.
For food companies, dairy processors, ingredient suppliers, and sustainability teams, this may become far more than a technical update.
It could reshape:
how product footprints are calculated,
which environmental indicators matter most,
how farm-level performance is represented,
and how defensible sustainability claims become.
A broader environmental lens beyond carbon
One of the clearest signals from the EF review discussions is the move toward broader environmental assessment.
Current proposals suggest the EF framework may expand from 16 to 18 impact categories, including:
land-use biodiversity impacts,
and physical impacts from microplastics and microfibers on biota.
This reflects a wider shift already emerging across sustainability policy and science:
Carbon remains important, but it is no longer sufficient on its own.
For food companies, this means products may increasingly be evaluated not only on greenhouse gas emissions, but also on:
biodiversity impacts,
soil quality,
material persistence,
and agricultural land management practices.
The review process strongly suggests a move away from what many sustainability practitioners describe as “carbon tunnel vision.”
Agriculture is moving closer to the center of EF modelling
For the food and dairy sectors, the agricultural revisions may ultimately become the most consequential part of the EF update.
The Agricultural Working Group presented several proposed methodological upgrades, including:
more advanced fertilizer emissions modelling,
pesticide modelling through OLCA-PEST,
improved manure and feed digestion modelling,
integration of Soil Organic Carbon (SOC),
biodiversity modelling through BioMAPS,
and stronger primary data requirements at farm level.
Together, these developments point toward a significant methodological shift:
From highly averaged agricultural modelling toward more granular representation of real farm practices.
Under many current footprinting approaches, differences between farms can become flattened into generalized datasets.
The emerging EF direction suggests that:
nutrient management,
feed sourcing,
manure handling,
biodiversity conditions,
and soil practices
may increasingly influence product-level outcomes.
For sectors like dairy where farm-stage emissions dominate much of the footprint — this could materially affect both results and competitive positioning.
Biodiversity is becoming operational, not optional
One of the most important strategic developments is the growing integration of biodiversity into environmental footprinting.
The EF review discussions include proposals to:
revise land-use impact modelling,
integrate Soil Organic Carbon into soil quality assessment,
and introduce biodiversity impact assessment linked to land occupation and transformation through the BioMAPS model.
While biodiversity methodologies are still evolving, the direction is clear:
Biodiversity is moving closer to the center of environmental performance assessment.
For companies investing in:
regenerative agriculture,
pasture-based systems,
biodiversity programs,
or soil health initiatives,
this could become strategically important.
Better farm-level data may increasingly support differentiation — provided the underlying evidence is robust and verifiable.
Electricity modelling remains highly debated
Electricity accounting appears to be one of the most contested areas in the EF review.
Current discussions explore a more restrictive and standardized hierarchy, potentially prioritizing:
on-site electricity generation,
followed by national average consumption mixes,
with tighter conditions around contractual instruments and supplier-specific claims.
At the same time, several EF stakeholders have raised concerns that overly standardized electricity modelling could:
flatten regional differences,
weaken incentives for low-carbon procurement,
and reduce the value of supplier-specific data collection.
As a result, the final approach remains under active discussion.
For companies relying heavily on renewable electricity claims, PPAs, or market-based accounting approaches, this is an area worth monitoring closely.
Data quality may become a competitive differentiator
Across nearly all EF review topics, one common theme emerges:
Higher expectations around data quality, transparency, and methodological defensibility.
The review discussions include:
stricter and more streamlined Data Needs Matrix requirements,
increased use of primary data,
expanded flexibility for ILCD-compliant datasets,
stronger uncertainty assessment,
and more formalized verification approaches.
In practical terms, this suggests sustainability reporting may increasingly depend on:
traceable supply-chain data,
product-specific modelling,
and auditable calculation systems.
The strategic implication is significant:
Environmental claims may rely less on generic averages and more on operational data infrastructure.
Verification is becoming more rigorous
The EF review also points toward more structured governance and verification requirements.
Topics under discussion include:
verified EF tools,
lighter verification pathways for pre-verified systems,
stronger governance of PEFCRs,
and more explicit verification requirements for company-specific processes.
For many companies, this may represent a transition away from spreadsheet-based sustainability assessments toward more formalized and auditable systems.
The direction is increasingly clear:
Defensibility matters.
What this could mean for food companies
Taken together, the EF review discussions point toward a broader market transition:
From simplified environmental reporting toward evidence-intensive environmental accountability.
Companies that may benefit most are likely those with:
strong supplier integration,
access to farm-level primary data,
product-specific LCA capability,
and robust sustainability data governance.
At the same time, companies relying primarily on:
carbon-only narratives,
generic databases,
weak supplier traceability,
or lightly substantiated environmental claims
may face growing pressure.
Why dairy could be particularly affected
Dairy may become one of the sectors most exposed to these methodological changes because many of the newly emphasized topics are already central to dairy footprinting:
methane emissions,
fertilizer management,
feed sourcing,
biodiversity,
soil carbon,
and farm-level variability.
As modelling becomes more granular, the industry may gradually move away from the idea of a single “average milk footprint” toward more differentiated representations of production systems and farm practices.
That creates both risk and opportunity.
Risk
Poor data quality may increasingly weaken claim defensibility.
Opportunity
High-quality farm data and transparent modelling may support stronger positioning, especially for producers investing in regenerative or differentiated production systems.