Why PEF Needs to Rethink Land Use
Land use is a fundamental environmental factor for agricultural products, including natural fibres. For wool, land is the basis of production and a resource that must be actively managed. This makes land use more than simply an input to be counted.
The way land use is measured in models like the EU Product Environmental Footprint (PEF) will influence policy, product comparisons, and consumer information down the line.
Grazing sheep on semi-arid land is not the same as occupying fertile land, or land in a densely populated region. The current land use method in PEF struggles to reflect that difference.
Because wool production often happens on land where alternative uses are limited, it is important to get this right.
Through the Lens of LANCA
The current PEF approach uses the LANCA model – LANd use indicator value CAlculation – to assess land use impacts. LANCA was introduced to move beyond a simple “area occupied” approach by considering soil quality and ecological functions. However, its current implementation is creating misleading results for extensive, lower-intensity farming systems typical for wool-growing.
A central concern is that land use impact in LANCA increases with the amount of land used per unit of product. This penalises extensive grazing systems, even where those systems are associated with good soil management, biodiversity outcomes, and low levels of inputs.
By contrast, more intensive systems appear more favourable simply because they use less land per unit of output.
LANCA also relies heavily on reference conditions and default data. In practice, many assessments use national averages that do not reflect the vastly varying soils, climate, land productivity, or management practices that exist across wool-growing countries. In large and diverse countries, this lack of regionalised data produces results that are not representative of the reality of wool-growing.
Another limitation is that LANCA compares current land use to an idealised natural reference state. Simultaneously, improvements in soil health or good land stewardship are not recognised.
The result is a method that is better at recording land occupation than at rewarding sustainable land management.
Rethinking Land Use Measurement
Wool is often produced in extensive grazing systems, including rangelands and semi-arid areas where alternative land uses may be limited. Treating all land as equally scarce or equally productive risks overstating the impact of such systems.
Grazing sheep on semi-arid land is not the same as occupying fertile land in a densely populated region, yet LANCA struggles to reflect that difference – meaning it won’t be reflected in the PEF, either.
Good grazing and environmental management can support important ecosystem functions, including nutrient cycling, water retention, and biodiversity. These outcomes depend on local context and management practices, which is why land use assessments need to be geographically relevant and reflect positive farm management practices.
If these factors are not reflected, natural fibres produced in extensive systems may receive artificially high impact scores. This creates biased comparisons with synthetic materials and misinforms policy decisions or consumer-facing claims.
What a Better Approach Should Include
Land use indicators should:
Move beyond national averages and incorporate regionally relevant data;
Use realistic baselines rather than idealised or unavailable natural reference states;
Recognise improvements in soil health and sustainable land management practices;
And Avoid systematically penalising extensive, low-input systems simply because they use more land per unit of output.
IWTO Calls for a Fair and Science-Based Measurement
As the EU continues to refine the PEF, land use indicators must be capable of distinguishing between land occupation and land management. Without this distinction, PEF risks overlooking sustainable practices and sending the wrong signals to producers, policymakers, and consumers.
A revised approach to LANCA in PEF would help ensure that environmental information reflects what is actually happening on the land and supports the transition to more sustainable production systems across natural fibre production systems.
Source: by Elizabeth Van Delden Sustainability Manager Europe at Woolmark & Make the Label Count (MTLC)

Sustainability Manager Europe at Woolmark & Make the Label Count (MTLC)
Elisabeth started working in the wool industry in 2011 when she joined the International Wool Textile Organisation. Here she developed her passion for wool and gained expertise in navigating the EU’s legislative processes. Before joining Woolmark, she consulted with natural fibre companies along the entire supply chain, from farm to fashion. In her role as Campaign Manager for Make the Label Count, Elisabeth advocates for a level playing field for natural fibres within EU textile legislation.
