PAS 2090:2025 is a free, voluntary BSI specification for the life cycle assessment of medicines, including their carbon footprint. It adds pharma-specific rules to ISO 14044 and ISO 14067.
No law requires it. The pressure comes from customers: nine pharma and biomanufacturing companies in the SMI Health Systems Task Force have asked suppliers to disclose footprints for their top 10 products by 2028, following PAS 2090 for medicines, and asked contract manufacturers for primary data compatible with it.
NHS England plans product footprinting requirements from April 2028, with scope and method still to be agreed. Norway is piloting PAS 2090 in hospital tenders; France encourages its own medicine carbon score.
Making the active ingredient usually dominates a medicine's footprint, so the data that matters most often sits with contract manufacturers and ingredient suppliers.
The company preparing a footprint may use secondary data and documented proxies for activities outside its operational control, labelled as such. If you are the contract manufacturer, your own processes are inside your control, and customers will expect primary data from you.
PAS 2090 is a rulebook for measuring the environmental footprint of a medicine. BSI, the UK's national standards body, published it on 30 November 2025, with support from NHS England, the UK Office for Life Sciences and the Pharmaceutical LCA Consortium. It is free to download and voluntary. Even so, it already matters to many pharma suppliers: nine large pharma and biomanufacturing companies have asked their suppliers to disclose product carbon footprints or LCAs for their top 10 products by 2028, to follow PAS 2090 for medicines, and, for contract manufacturers and materials suppliers, to provide primary data compatible with it.
This page explains what the standard asks for, who is likely to ask you for a PAS 2090 footprint, and what a mid-sized pharma company or contract manufacturer needs to have ready.
| Question | Answer |
|---|---|
| Full title | PAS 2090:2025, Pharmaceutical products. Product category rules (PCR) for environmental life cycle assessments. Specification |
| Who published it | BSI (British Standards Institution), committee ZZ/5 |
| When | 30 November 2025 |
| Who supported it | NHS England, the Office for Life Sciences and the Pharmaceutical LCA Consortium |
| Who is in the consortium | AstraZeneca, GSK, Johnson & Johnson Innovative Medicine, Merck KGaA, MSD, Novartis, Novo Nordisk, Pfizer, Roche, Sanofi and Takeda; the consortium's own website also lists Chiesi |
| Who wrote the text | Quantis, as BSI's appointed author, with the consortium |
| What it costs | Nothing. BSI offers a free download |
| Is it law | No. It is voluntary. The SMI targets point medicine makers to it, and NHS England plans product footprinting requirements from 2028, method still to be agreed |
| What it sits under | ISO 14040 and 14044, the general rules for life cycle assessment; it adds pharma detail to ISO 14067, the carbon footprint standard |
| What it measures | The EU Environmental Footprint impact categories, with climate change one of them. A carbon-only footprint is allowed |
| What products you can use it for | Licensed medicines for human use, including their active ingredients. The footprint can cover the drug substance, the finished product, any device that is part of the medicine (such as a prefilled pen), packaging, distribution, patient use and disposal |
| What products you cannot use it for | Standalone medical devices, diagnostic products, and unlicensed or custom-made medicines. These need different rules |
| What it does not assess | Research and development of the medicine, and the wider patient care pathway around it (the clinic visit, the nurse's time) |
A product carbon footprint (PCF) counts the greenhouse gases emitted to make, move, use and dispose of one unit of a product. ISO 14067 says how to do that for any product. It leaves open the choices that make two footprints of the same tablet come out different: where the measurement starts and stops, how to divide a factory's energy between the dozens of products it makes, whether the patient's trip to the pharmacy counts, what to do with the part of a pack that is never used.
Hospital buyers noticed. Norway's hospital procurement agency, Sykehusinnkjøp, has scored environmental criteria in medicine tenders for several years and found that, without one method, supplier footprints were hard to compare. That is one reason it is now piloting PAS 2090.
Product category rules close those choices for one type of product, so that two companies following them get comparable results. The Pharmaceutical LCA Consortium, launched in November 2023 under the Pharmaceutical Environment Group and the Sustainable Markets Initiative (SMI) Health Systems Task Force, co-developed the standard with Quantis. BSI's public consultation in June 2025 drew more than 400 comments, and more than 475 stakeholders in 35 countries took part in developing it.
Say what one unit is. Every study names a "declared unit": one unit of product as manufactured, packaging included. For example: one pack of 32 paracetamol tablets at 500 mg, ready to ship. If you want to compare two medicines you also need a "functional unit", such as one patient treated for one year.
Say where you start and stop. You can measure from raw materials to your factory gate ("cradle to gate") or all the way to disposal ("cradle to grave"), but you must say which. Everything that goes into making the product counts. Buildings, equipment and research count only when they matter to the question you are asking, and you must say so.
Count every ingredient. For the drug substance and the finished product, you may not leave out small ingredients. If you leave anything out elsewhere, you report it and justify it.
Divide shared energy fairly. When a site makes several products, you split its energy between them by a physical or causal measure (hours, batches, mass), and you document the method. Combined heat and power follows the PAS 2050 method. Recycled content follows the "recovered content cut-off" approach, and you take no credit for recycling at the end of life.
Build a proxy when a chemical has no data. Where a purchased chemical has no supplier dataset, you model it from its chemistry: the reaction, the yield, the energy, solvent, catalyst, water and waste. Raw materials count as 100 percent virgin unless you know the recycled content.
Include packaging and the cold chain. Primary, secondary and tertiary packaging are in. For storage you do not control, the standard provides default energy and refrigerant data for ambient, chilled (2 to 8 °C) and frozen (minus 18 °C and below) conditions, and transport datasets for refrigerated trucks and containers.
Include the patient. Consumables listed in the instructions for use count. The standard defines the patient's travel to the place of treatment as a stage with default data; if you leave it out you still report it in an annex. Overfill and the overage that is thrown away count. The fossil carbon in the active ingredient and its metabolites is counted as emitted to air.
Report electricity two ways. Where you buy renewable electricity contracts, you report both a "market-based" figure (with your contracts, using the residual mix for the rest) and a "location-based" figure (the grid average).
Label every number. For each life-cycle stage and each impact, you name the biggest contributor and say whether that number came from your own measurements (primary data), a database (secondary data) or a model (proxy). Clause 5.1.1 sets out where supplier-specific data is expected. BSI has confirmed that the company preparing the footprint does not need primary data for activities outside its operational control. A contract manufacturer's own processes are inside its control, which is why customers ask contract manufacturers for primary data. The consortium's Technical Guidance (v1.1, April 2026) names a reference background database.
Get it checked when you compare. PAS 2090 does not require a third-party check for every study. An internal review is enough for an internal cradle-to-gate study. A public claim that compares products needs an independent critical review under ISO 14044. The SMI targets do not mention verification of product footprints.
| Who asks | What they ask for | When |
|---|---|---|
| SMI Health Systems Task Force (AstraZeneca, Chiesi, GSK, Novartis, Novo Nordisk, Roche, Samsung Biologics, Sanofi, UCB) | Product carbon footprints or LCAs for your top 10 products by emissions; medicines to follow PAS 2090; contract manufacturers and materials suppliers asked for primary data compatible with standards, citing PAS 2090 clause 5.1.1 as an example | By 2028 |
| The same companies, in their chief procurement officers' letter of 21 November 2025 | Build the same targets into contracts with your own suppliers | Now |
| NHS England Net Zero Supplier Roadmap | Carbon footprinting requirements for individual products. A June 2026 market survey proposed a gradual rollout from priority products and framework renewals, a method aligned with emerging international standards, and no LCA for every product. NHS England says these are proposals, with policy still to be agreed | Planned from April 2028 |
| Sykehusinnkjøp (Norway's hospital procurement agency) | Piloting PAS 2090 by writing consistent environmental information requirements into tender documents and encouraging suppliers to provide validated carbon footprints | Pilot under way |
| NICE (UK) | Piloted PAS 2090 to test the use of environmental data in health technology assessment | Pilot |
| French public procurement | Procurements launched from August 2026 must include at least one environmental award criterion, with limited exceptions. For medicines, the health ministry encourages a carbon score built on a separate French method (ISO 14067 plus the GHG Protocol, per pack and per daily dose, for 18 priority molecules); buyers use it voluntarily | From August 2026 |
If you are a contract manufacturer or active ingredient supplier to any of the SMI companies, expect a request for primary data on your processes, compatible with PAS 2090 clause 5.1.1, so your customers can build their medicine footprints before 2028. If you sell generics or over-the-counter medicines to the NHS, watch for NHS England's product requirements, which are likely to start with priority products.
The consortium reports the same pattern from its pilots at GSK, Sanofi and Novo Nordisk: making the drug substance caused most of the impact; shipping and patient use mattered in some cases; turning the substance into tablets or vials, and disposal, mattered least. So the data that matters most describes how the active ingredient is made, and for most mid-sized companies a contract manufacturer holds it.
From the Technical Guidance, you need:
For a consumer health company with dozens of contract manufacturers, the fifth item is the hard one. A contract manufacturer can often give you its site's Scope 1 and 2 total but little at product level. The standard allows for this: the company preparing the footprint may use secondary data and documented proxies for activities outside its operational control, labelled as such. The consortium's pilots found that supplier engagement and data availability, more than method, set the pace.
Few pharma companies will have primary data from every contract manufacturer by 2028. Terrascope builds footprints from the data you already hold and labels what is modelled, so you can start now and replace estimates with supplier data as it arrives. Pokka, a beverage company, footprinted 4,980 products without supplier data; checked against actual data for 700 of them, the models were about 92 percent accurate. Beverage bills of materials are simpler than active ingredient synthesis, so in pharma the accuracy of a modelled footprint depends on the quality of the chemical proxies. iNova Pharmaceuticals mapped emissions across 700+ SKUs made by third-party manufacturers, using AI-powered matching of activity data to more than 50,000 emission factors, and gained its first complete, audit-ready baseline.
With experts built in: Terrascope's sustainability team scopes the footprint with you and documents the method, so your customer's LCA team can follow how each number was built.
If a customer has asked for footprints on your top products, or you supply one of the SMI companies, book a demo with a Terrascope sustainability specialist. You will leave knowing which data you already have and what a footprint built on PAS 2090's rules still needs.
Sources: BSI PAS 2090:2025 product page and launch press release (1 Dec 2025); Pharmaceutical LCA Consortium Technical Guidance v1.1 and Supplier FAQ; SMI Health Systems Task Force supplier targets, CPO letter and toolkit; NHS England Net Zero Supplier Roadmap; BSI case studies on the NHS England, NICE and Sykehusinnkjøp pilots; Quantis; EFPIA; Projet Celsius; PharmaLCA; SimaPro. Accessed October 2026.