Product Life-Cycle Assessments: Integrating Circular Economy Metrics
Brave Horizons paused new publications between 1 August and 15 September 2026 — a planned break, not a change in direction or commitment to the series. In our last article before the pause, Green Finance Incentives: Leveraging Sustainable Loans for Retailers, we examined how the EBA’s ESG risk guidelines, the 2025 update to the Sustainability-Linked Loan Principles, and the Empowering Consumers for the Green Transition (ECGT) Directive are converging on retail financing decisions in 2026. This article resumes that cadence and turns from financing sustainability claims to substantiating the product claims that sit behind them.
The useful question is not “how circular is this product?”
Recycled content and environmental performance are related, but they are not interchangeable. Circularity indicators can conceal burden shifting when recycling adds energy use or emissions. Packaging rules also distinguish design for recycling from collection, sorting and recycling in practice (Barrak et al., 2024; European Parliament and Council, 2025). Product lifetime changes the result only when longer use, repair and recovery assumptions hold in practice (Cilleruelo Palomero et al., 2024).
These trade-offs are the reason to measure environmental impact and circularity together. A useful dashboard should expose the assumptions behind the decision rather than compress them into one score.
On 17 July 2026, Commission Implementing Regulation (EU) 2026/1778 was published for the Digital Product Passport registry under the Ecodesign for Sustainable Products Regulation. It defines registry roles, verification of economic operators, automated checks on submitted data structures and audit logs. The automated checks do not replace authorities' assessment of substantive correctness (European Commission, 2026). For an SME, the practical response is a proportionate product-data process that combines life-cycle assessment with circularity indicators and increases analytical depth when the decision or claim is material.
Two lenses, two different questions
Life-cycle assessment (LCA) compares environmental impacts for a defined product or service system. A usable comparison states the decision, functional unit, system boundary, inventory assumptions and impact indicators. 'One chair' is not the same functional unit as 'ten years of seating', and a cradle-to-gate study does not answer the same question as a cradle-to-grave assessment (Barrak et al., 2024). Carbon can be one indicator, but a decision may also require evidence on energy, water, toxicity or resource use.
Circularity measurement asks how products, components and materials remain in use and retain value. The Organisation for Economic Co-operation and Development recommends sets of indicators across the material life cycle rather than one isolated measure (OECD, 2024). Product-level research identifies durability, repair, reuse, refurbishment, remanufacturing and safe recovery as relevant attributes, while also documenting gaps in existing assessment methods (Ko et al., 2024). The CERE framework translates part of this logic into practical indicators for small and medium-sized enterprises in the chemical industry; its authors caution that some product-use indicators do not fit that sector (Vogt et al., 2025).
Used together, the two lenses test whether a product choice preserves value and reduces environmental impact for the required function without shifting a material burden elsewhere.
Why one circularity score can mislead
Circularity percentages look comparable, but the result depends on the indicator, boundary and evidence.
Consider a hypothetical retailer comparing two packaging formats. Option A uses more recycled content. Option B uses less material and may reduce damage in transit. A recycled-content indicator may favour A, while an LCA may favour B if energy, transport and product loss are included. The functional unit could be '1,000 undamaged deliveries'. The example does not predict the winning option; it shows why the comparison must use the same function, boundary and evidence for both alternatives (Barrak et al., 2024).
Durability creates the same measurement problem. A product may use more material at manufacture but have a lower impact per year of service if customers use it longer. That conclusion depends on documented lifetime, repair behaviour and end-of-life assumptions. Peer-reviewed studies find that circularity indicators and LCA results can diverge, and that product-level indicators may omit supply-chain material, energy and waste flows (Barrak et al., 2024; Cilleruelo Palomero et al., 2024). Keep the indicators visible, record the assumptions and explain the trade-offs.
The regulatory direction raises the value of good product data
The Ecodesign for Sustainable Products Regulation (ESPR) creates a framework for product requirements that may cover durability, repairability, recycled content, resource use, recyclability, recovery and environmental footprint (European Parliament and Council, 2024a). The Commission's 2025-2030 working plan prioritises iron and steel, aluminium, textiles, furniture including mattresses, tyres and other groups. It also includes horizontal work on repairability and on recycled content and recyclability for electrical and electronic equipment (European Commission, 2025b). Detailed obligations arrive through product-specific or horizontal measures, so they do not apply uniformly to every SME product today.
Directive (EU) 2024/1799 requires covered manufacturers to give consumers free access to indicative repair prices and supports access to information on repair services. Its duties depend on the goods covered by the Union acts listed in the Directive (European Parliament and Council, 2024c). The Corporate Sustainability Reporting Directive requires in-scope undertakings to report relevant information about their value chains, including products, services and supply chains (European Parliament and Council, 2022). The European Commission describes the voluntary VSME standard as a simplified reporting tool intended to replace a substantial portion of information requests that banks and large undertakings send to SMEs in their value chains (European Commission, 2025a).
The ECGT Directive (Directive (EU) 2024/825) strengthens consumer-protection rules for environmental and durability claims. Member States must apply the implementing measures from 27 September 2026 (European Parliament and Council, 2024b). For management, the control is an evidence file for each material claim: scope, method, source data, limitations, owner and review date.
A proportionate five-step method for SMEs
If you only do three things: name one accountable owner, choose a small pilot group based on exposure, and send suppliers one controlled data request instead of answering each questionnaire from scratch.
Begin with the decision
Do not start by buying software or designing a score. Start with a decision: selecting a packaging format, changing a material, extending a warranty, approving a supplier, redesigning a product, or substantiating a claim. Name the decision owner and the products affected.
Define the function and boundary
State the service being compared, such as hours of use, washes completed, kilometres travelled, deliveries protected or years of service. Record the life-cycle stages included. Do not present alternatives as directly comparable when their functions or boundaries differ.
Screen the portfolio before commissioning deep studies
Rank product categories using environmental-impact potential, revenue or spend, regulatory relevance, public claims exposure and data gaps. Choose a small pilot set that the team can evidence and review. Use recognised secondary data for screening, then obtain supplier-specific or independently verified data where the decision or claim is material.
Use a dashboard, not an opaque average
Keep at least these fields separate:
climate impact and any other decision-relevant LCA indicators;
virgin, renewable and recycled material shares;
expected service life and warranty;
repairability and spare-parts availability;
reuse, refurbishment or remanufacturing pathways;
packaging mass per functional unit;
actual or credible collection and recovery outcomes;
supplier-data coverage, age and assurance
A single total score can conceal burden shifting or weak evidence. A dashboard keeps separate indicators and their data quality visible so that leaders can set thresholds and approve documented exceptions (Barrak et al., 2024; Cilleruelo Palomero et al., 2024).
Grade the evidence and apply gates
For internal governance, use a simple evidence scale. Grade A is independently verified primary data. Grade B is supplier-specific documented data. Grade C is recognised secondary data or a sector average. Grade D is an assumption or gap. Proceed when both impact and circularity improve without a material burden shift. Add controls when the case is positive but evidence is incomplete. Test or redesign when the outcome depends on lifetime, recovery or supplier assumptions. Stop when a material claim cannot be substantiated or a critical threshold is breached.
What management should monitor
Indicator | Why it matters |
Share of relevant revenue covered by an assessment | Shows how much of the exposed portfolio is actually understood |
Supplier-data completeness for priority products | A gap here is a gap in every other number below it |
Verified secondary-material content, by mass | Distinguishes a real material shift from a rounding claim |
Expected service life and documented use assumptions | Shows whether a durability claim changes the result under stated use conditions |
Repair readiness — parts and service availability | Repairability without access is a claim, not a capability |
Packaging weight per functional unit | Keeps damage and material trade-offs visible together |
Verified recovery or reuse, not technical recyclability alone | Separates technical recyclability from documented collection and treatment outcomes |
Share of environmental claims with an approved evidence file | Turns ADR-007-style discipline into a governance metric, not just a research rule |
Unresolved exceptions where one impact improves and another worsens | Surfaces the trade-offs a single score would have hidden |
The indicators do not need to be exhaustive before they support a decision. They do need defined methods, owners, source dates and review dates.
A practical roadmap
In the next 30 days, choose one product category and a manageable pilot set based on spend, revenue, claims and policy exposure. Define one functional unit and boundary. Ask suppliers for a controlled set of fields covering materials, manufacturing data, expected life, repair, packaging and end-of-life. Link every material environmental claim for those products to its evidence.
Over one to six months, run the dashboard and test the assumptions that could reverse the decision. Commission a deeper life-cycle study where screening identifies a high-stakes choice. Add product-data requirements to supplier onboarding and procurement, and establish thresholds and an approval route for exceptions.
Beyond six months, integrate controlled product information with product, procurement and compliance systems. Use the findings to redesign products, packaging, warranties and service models. Seek independent assurance for material claims and align records with applicable Digital Product Passport requirements as the relevant product measures take effect.
Conclusion
The objective is a reliable decision process, not a perfect circularity number. LCA identifies environmental consequences across a defined life cycle. Circularity indicators show whether products, components and materials remain in use. Combining them reduces the risk of improving an easy-to-communicate indicator while worsening another impact or relying on evidence that does not support the claim (Barrak et al., 2024; Cilleruelo Palomero et al., 2024).
Start with one category, one controlled dataset and one accountable decision. Record the assumptions, grade the evidence and escalate material trade-offs through the normal approval process. This makes product sustainability part of enterprise risk management and keeps public claims tied to evidence.
Where this fits in the series
This builds on the financing perspective covered in Green Finance Incentives: Leveraging Sustainable Loans for Retailers (Amaranth Brose, 21 July 2026). The European Investment Bank notes that the absence of accepted circularity metrics complicates credit assessment and investment decisions (European Investment Bank, 2026).
What's Next
If your product teams cannot answer sustainability questionnaires consistently, Amaranth Brose can help you design a proportionate product-risk and evidence framework. → Book a risk-advisory conversation
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