Packaging and transport are visible parts of a pharmaceutical product’s environmental footprint, but they are not automatically its biggest impacts. Significant hotspots can sit further upstream in active pharmaceutical ingredient (API) production, chemical inputs, energy use and outsourced manufacturing. For other products, the administration device, cold chain, patient use or end-of-life route may be more influential.
There is no single hotspot for every medicine. Results depend on the formulation, manufacturing route, geography, packaging, delivery method and intended use. Identifying environmental hotspots in pharmaceutical supply chains therefore requires evidence across the product life cycle.
PAS 2090:2025 provides a consistent framework for doing this by establishing product category rules specifically for pharmaceutical Life Cycle Assessments (LCAs). It can help organisations understand where impacts occur and where changes could deliver the greatest benefit.
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An environmental hotspot is a material, process, supplier, location or life-cycle stage that makes a significant contribution to one or more environmental impacts. The same stage may not dominate every category. Manufacturing could be the largest source of greenhouse gas emissions, while raw materials create more pressure on water or natural resources. Packaging might contribute less to climate change but remain important for waste.
A pharmaceutical Life Cycle Assessment should therefore consider more than carbon alone. This helps avoid burden shifting, where reducing one impact unintentionally increases another.
PAS 2090:2025 covers pharmaceutical products for human use, including the drug substance, formulation, an administration device where applicable, packaging, distribution, patient use and end of product life. It also addresses boundaries, data quality, assumptions, allocation and multiple environmental indicators.
Product environmental evidence is particularly relevant to healthcare procurement. The NHS Net Zero Supplier Roadmap, published in June 2026, confirms that new requirements overseeing carbon footprint information for individual products will be introduced from April 2028. The NHS will work with suppliers and regulators to determine the scope and methodology.
PAS 2090 is voluntary and is not itself an NHS tender requirement. However, it provides a consistent method for building a product’s evidence to support reduction planning, product development, procurement and credible communication.
API production can involve several synthesis stages, specialist chemicals, solvents, catalysts, purification and substantial energy use. Poor yields increase the materials and energy needed for each unit of finished API, while waste treatment creates further impacts.
A 2024 critical review of pharmaceutical LCA studies identified energy consumption, particularly electricity, and chemical use as leading contributors. It also highlighted the importance of toxicity impacts associated with active compounds.
Geography is also important because results vary with the local electricity mix, water pressures and waste infrastructure. Where supplier data is limited, an assessment can combine available primary information with suitable secondary data and identify where better evidence would most improve confidence.
Turning an API into a finished product creates another potential set of hotspots. Heating, ventilation and air conditioning, purified water, steam, refrigeration, sterilisation and cleaning may all contribute. The balance will differ between tablets, liquids, biologics, vaccines and other products.
Product losses and rejected batches carry the impacts of resources already used. For outsourced production, transparent allocation is needed to assign facility-wide impacts to an individual product.
Packaging protects stability, sterility, safety and regulatory compliance. Blister packs, bottles, vials, syringes and temperature-control materials all contribute to the environmental impact of medicines. Reducing packaging weight may appear beneficial, but a change that causes greater product loss or temperature excursions could create a larger overall impact than it saves.
PAS 2090 includes an administration device where it forms part of the pharmaceutical product system, such as an inhaler or injector. It does not cover standalone medical devices. Those products require a separate LCA approach, typically aligned with ISO 14040 and ISO 14044.
This distinction is important when considering medical device environmental impact. A 2025 systematic review of 59 medical device studies found that production and manufacturing were common carbon hotspots for single-use devices, while reprocessing was the main hotspot for reusable alternatives. Reuse can move the hotspot rather than remove it, reinforcing the need for product-specific assessment.
Pharmaceutical supply chains connect manufacturing sites, packaging facilities, distribution centres and markets. Air freight, refrigerated transport, temperature-controlled storage and insulated packaging can make logistics significant for temperature-sensitive products.
Distance alone does not prove that freight is the largest contributor. A pharmaceutical Life Cycle Assessment may show that manufacturing or the delivery system has a greater impact.
The use phase may be minimal for some medicines and dominant for others. Metered-dose inhalers are a familiar example because propellants released during use can strongly influence climate impact. Preparation losses, administration consumables and product wastage may also matter.
End-of-life routes include unused medicines, contaminated packaging, administration devices, sharps, incineration and wastewater. Active pharmaceutical compounds released into the environment may create toxicity and ecological impacts that a carbon footprint does not show.
Modelling should reflect realistic disposal routes. Describing packaging as recyclable can overstate performance if suitable collection and treatment infrastructure is not available where the product is used.
A PAS 2090 assessment gives pharmaceutical organisations a structured route from supply chain data to practical priorities:
Define the decision.
Establish whether the assessment will support product development, supplier engagement, procurement, reduction planning or environmental claims.
Map the life cycle.
Identify relevant materials, suppliers, locations, packaging, distribution routes, use assumptions and disposal scenarios.
Build the inventory.
Combine primary operational and supplier data with appropriate secondary datasets, recording assumptions and data limitations transparently.
Assess multiple impacts.
Use contribution analysis to identify which stages influence each environmental category most strongly.
Test improvements.
Model options such as renewable electricity, higher process yields, alternative solvents, packaging redesign or different transport and disposal routes.
This process can focus action on the areas with the greatest potential, whether that means engaging a high-impact supplier, improving manufacturing efficiency, reviewing chemical use, redesigning packaging or reducing product losses. Any proposed change must also be considered alongside patient safety, efficacy, quality, regulatory requirements and supply continuity.
Environmental hotspots in pharmaceutical supply chains are rarely limited to one visible component. They may lie within API synthesis, outsourced production, energy use or chemical inputs, while other products are more heavily influenced by packaging, administration, cold-chain distribution, patient use or end of life.
PAS 2090 helps pharmaceutical organisations investigate these impacts using a consistent, science-based methodology. For medical device manufacturers, the route differs because combination products may include an administration device within the PAS 2090 boundary, but standalone devices require a separate LCA. In both cases, credible pharmaceutical supply chain sustainability begins with assessing where impacts occur.
Tunley Environmental supports pharmaceutical and medical device organisations with science-based Life Cycle Assessments, supply chain analysis and environmental reduction planning. Explore our PAS 2090 Life Cycle Assessment service or our sustainability solutions for pharmaceutical and medical device organisations to learn more.