What is PAS 2090?

The pharma-specific standard for life cycle assessment

PAS 2090:2025 is a BSI specification that sets product category rules (PCR) for environmental life cycle assessments (LCA) of pharmaceutical products for human use, and for reporting the results. Published on 30 November 2025, it gives the pharmaceutical industry a harmonized, internationally applicable framework for assessing the environmental impact of pharmaceutical products across relevant life-cycle stages, supporting both cradle-to-gate and cradle-to-grave assessments.

Key Facts

PAS 2090 at a glance

Full title

PAS 2090:2025 Pharmaceutical products. Product category rules for life cycle assessments. Specification

Publisher

BSI (British Standards Institution)

Published

30 November 2025

Sponsors

NHS England, the Office for Life Sciences and the Pharmaceutical LCA Consortium, with the SMI Health Systems Task Force and PEG

Scope

Pharmaceutical products for human use, cradle-to-gate and cradle-to-grave. Intended to be applicable internationally

Status

Voluntary, with no new regulatory obligations

Availability

DRM-free download from BSI 

Scope

What does PAS 2090 cover?

PAS 2090 covers pharmaceutical products for human use across their whole life cycle.

PAS 2090 sets rules for

  • LCA goal, declared and functional units
  • System boundaries and life cycle stages
  • Multiple environmental impact category indicators
  • Allocation rules, cut-off criteria and assumptions
  • Data quality, primary data and secondary data selection
  • Interpretation, reporting and documentation

PAS 2090 does not cover

  • Medical diagnosis products
  • Standalone medical devices, as defined by the UK Medical Devices Regulations 2002
  • Unlicensed or custom medicinal products made on specific medical advice
  • Assessment of patient care pathways
  • Assessment of development (the research and development phase)
  • Environmental product inventory factors (the standard sets the rules for an assessment, it does not supply the underlying data)

Expert view

In practice, the most sophisticated LCA setup is rarely the best place to start PAS 2090 implementation. What matters is choosing an approach that fits the goal and scope of the assessment and the decision the results need to support.

Dr. Leif Rohrbach

Pharma Sector & Project Lead, Carbon Minds

In practice

What does an assessment under PAS 2090 involve?

The standard sets rules for each step of an environmental LCA of a pharmaceutical product.

01

Define goal and scope

Set the intent of the assessment, the declared and functional unit and what the results will be used for.

02

Set system boundaries

Define which life cycle stages are included, along with cut-off criteria, assumptions and allocation rules.

03

Apply primary-data requirements

Use primary data in line with PAS 2090 requirements. Primary data is not required for activities outside a company’s operational control.

04

Select and document secondary data

Choose representative background data for the rest of the life cycle and document the choices and their quality.

05

Calculate the results

Calculate the environmental impacts across the relevant impact category indicators, applying the system boundaries, rules and data defined in the previous steps.

06

Interpret and report

Interpret the results and report and document them according to the rules set out in the standard.

In practice

What does PAS 2090 mean for pharmaceutical companies?

PAS 2090 gives the industry a common framework for environmental assessments and places clear requirements on data quality, transparency and the selection of representative background data.

 

PAS 2090 does not require primary data for activities outside a company’s operational control. This makes the selection of suitable secondary data particularly important for upstream supply-chain activities.

In 90 seconds

What PAS 2090 requires for every raw material

Dr. Arne Kätelhön, Co-Founder and Managing Director of Carbon Minds, explains how PAS 2090 helps to decide whether a chemical input needs detailed modeling or whether a proxy is enough, and what the 3% rule means in practice.

 

From our webinar “Pharma LCA & PAS 2090: Closing Data Gaps Before New Requirements Take Effect”.

How Carbon Minds supports you

How we support your PAS 2090 compliance

Turning pharma LCA requirements into a consistent, scalable process requires the right methodology, reliable data and a clear implementation approach.

Plan and scale your LCA approach

Our Pharma LCA Implementation Services help you define your goals, assess your current setup and build a roadmap for implementing and scaling PCF and LCA across your portfolio. Support can range from strategic alignment and training to company methodologies, pilots and portfolio-wide rollout.

Access granular raw material data

PAS 2090 recommends data with high technological or geographical accuracy where available. Our technology- and region-specific datasets for chemicals and pharmaceutical precursors provide that level of detail.

Close data gaps

Where data gaps remain, we help define the required data quality and close them with the right approach. From scalable proxy selection to dedicated custom modeling, we match the modeling effort to the material and intended use.

Build on a certified foundation

Our methodology and processes are certified by TÜV Rheinland for compliance with relevant standards, providing a credible basis for PCF calculations and LCA studies.

The Carbon Minds Database supports PAS 2090:2025 compliance

The Carbon Minds Database V2.03 (2026) is suitable for use in PAS 2090-compliant studies, as verified by TÜV Rheinland. 

Comparison

How does PAS 2090 relate to ISO 14040, ISO 14044 and ISO 14067?

PAS 2090 does not replace the general ISO standards. It adds pharma-specific rules for how to apply them.

ISO 14040 / 14044 ISO 14067 PAS 2090
Publisher ISO ISO BSI
What it is International standards on life cycle assessment Requirements and guidelines for the carbon footprint of a product (CFP) Pharma-specific product category rules for environmental LCA
Sector All sectors All sectors Pharmaceutical products for human use
Impact categories Selected per study, not limited to one Climate change only Multiple, including greenhouse gas emissions
Relationship General LCA framework Consistent with ISO 14040 and 14044 Adapts recognized international standards to pharma

Regulatory context

Why is PAS 2090 relevant now?

United Kingdom

NHS Net Zero Supplier Roadmap

From April 2027, the NHS will introduce new proportionate requirements for suppliers to publicly report targets and emissions and publish a Carbon Reduction Plan covering relevant global Scope 1, 2 and 3 emissions.

 

From April 2028, new requirements are planned for carbon footprinting of individual products supplied to the NHS. The NHS will work with suppliers and regulators to determine the scope and methodology.

France

Score carbone médicament

Score carbone médicament
France has its own public methodology for the carbon footprint of medicines, developed by the French ministries with the national health insurance fund. It covers climate impacts only and builds on the GHG Protocol and ISO 14067, so it sits alongside a PAS 2090 life cycle assessment rather than replacing it. Care institutions with their own pharmacy are encouraged to use the score as an award criterion, with a progressive rollout from 2026 starting with 18 priority molecules. Where a tender names the method, results calculated differently could be considered an irregular offer.

Good to know

Three questions we hear most often

Is PAS 2090 mandatory?

No. BSI describes PAS 2090 as voluntary, with no new regulatory obligations. It is a reference point to prepare for growing external expectations, for example from payors such as the NHS.

Does it only apply in the UK?

No. PAS 2090 was published by BSI in the UK, but it is intended to be applicable internationally.

Does it only cover carbon?

No. PAS 2090 covers multiple environmental impact category indicators, including the determination of greenhouse gas emissions.

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Upcoming

Roundtable・MID-DECEMBER 2026 (TBA)

Pharma Roundtable: practical implementation and open questions

Discuss PAS 2090, data gaps and practical implementation with our experts and your industry peers.

On-Demand Webinar

Pharma LCA & PAS 2090: Closing Data Gaps Before New Requirements Take Effect

Identify missing emission factors, prioritize the gap that matter and choose the right modeling depth.

On-Demand Webinar

Recent Advances in Environmental Life Cycle Data for Pharmaceuticals

Insights from Bayer and Carbon Minds on approaches to expand data coverage for pharmaceutical chemicals.

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