Agree on How to Measure. Then Improve Performance. How a new pharmaceutical standard illuminates a broader truth about system change.

Imagine trying to compare the environmental footprint of two medicines — only to discover that each company measures it in a different way. Different assumptions, different boundaries, different methods. The result is data that cannot easily be compared.

non PAS 2090 was developed in response to this challenge. Roche, Sanofi and nine other pharmaceutical companies, as part of the Sustainable Markets Initiative, worked alongside NHS England, the British Standards Institution and more than 475 stakeholders across 35 countries to create the first international standard for conducting product-level life cycle assessments (LCAs) in the pharmaceutical sector.

Published in December 2025, the standard establishes a consistent, science-based methodology for measuring the environmental footprint of medicines across their lifecycle – from molecule to manufacture, from supply chain to disposal. It is a deceptively simple distinction. But it contains, in condensed form, a principle that applies far beyond pharmaceuticals: before actors in a complex system can compete or collaborate meaningfully, they must first agree on how to see the problem.

The Infrastructure Nobody Talks About

System change has a visibility problem. The moments that capture public attention – landmark agreements, bold pledges, dramatic technological breakthroughs – are rarely where the real work of transformation happens. Much of what actually enables systems to shift is quieter, slower, and harder to narrate: the painstaking construction of shared standards, common languages, and agreed methodologies.

PAS 2090 is a case in point. Its significance lies in the fact that it establishes, for the first time, a shared basis for assessing greenhouse gas emissions and other environmental impacts for medicines. Before the standard existed, companies used different methodologies, system boundaries and assumptions when assessing product impacts. The result was data that could not easily be compared, supply chains that could not be benchmarked, and decisions that lacked a consistent evidence base.

The standard creates the conditions for collective action across an entire value chain. Standards, in this sense, are institutional infrastructure. Like roads or legal systems, they are most valuable when they are invisible – when they are simply the agreed ground on which everything else is built. Their absence is felt as friction, incomparability, and stalled coordination. Their presence enables things that were previously impossible.

From Measurement to Scale

The pathway from measurement to systemic change is not automatic. But it follows a recognisable logic – one that the PAS 2090 story makes concrete.

Shared language creates comparability. Comparability enables credible data. Credible data informs decision-making. And that enables healthcare systems to better understand the environmental impact of medicines and engage suppliers on reduction opportunities.

For Van Bergen, the standard helps identify environmental hotspots within Roche’s product portfolio and focuses attention on where reduction efforts will have the greatest impact. In short, measurement redirects what gets prioritised.

The effects of a shared standard can also be found at the system level. For Fiona Adshead, Chair of the Sustainable Healthcare Coalition, the example of NHS England speaks for this. NHS England – one of the world’s largest single purchasers of medicines – committed to measuring the carbon impact of all products by 2028. That commitment was a key driver in building the coalition that produced PAS 2090.  When a major buyer signals the information it will need—and helps build the tools to produce it—it begins to shape how suppliers across the market respond.

The pharmaceutical case is not unique in this respect. In agriculture, satellite monitoring and digital MRV systems are enabling the identification and verification of environmental hotspots at scale. In forest finance, measurable thresholds for credit integrity are reducing transaction complexity and unlocking capital that previously hesitated at the door. In insurance, risk modelling tools such as Swiss Re’s Biodiversity and Ecosystem Services Index are translating environmental change into financial exposure, making the invisible visible to markets that respond to price signals. In each case, the mechanism is the same: measurement reduces ambiguity, comparability enables decisions, and credible data moves capital.

The principle, abstracted from any single sector, is this: scaling complex systems depends on the ability to measure performance in consistent and comparable ways. Without measurement, coordination remains aspirational. With it, incentives can begin to align.

Beyond Carbon

The standard, in its current form, provides a life-cycle framework covering 16 environmental impact indicators, including climate, water use and biodiversity-related impacts. Companies can choose which of these indicators to assess and report, depending on their data maturity and priorities.

In practice, many organisations begin with carbon footprint measurement, where methodologies and data are currently the most developed. Carbon therefore often becomes the entry point. But as Bouttier-Stref noted, focusing on a single metric may create trade-offs: “By improving the climate footprint of our product, we could harm the waste footprint or the water footprint.” Optimising for one dimension without visibility across others is not progress. It simply shifts pressure elsewhere.

This tension is not unique to pharmaceuticals. It is a recurring feature of early-stage measurement frameworks across sectors. Carbon accounting preceded natural capital accounting. Financial reporting preceded social reporting. The pattern is consistent: we measure what is most tractable first, and then face the harder work of building the broader picture. The risk, at each stage, is that the partial view is mistaken for the complete one.

Measurement does not eliminate trade-offs. It makes them explicit and governable – if the measurement is broad enough to surface them.

From measurement to improvement

The pharmaceutical story offers a template: a multi-stakeholder coalition that includes industry, public institutions, regulators, and health systems; a process that takes the time to build genuine consensus; and an output that is practical enough to be implemented at different levels of data maturity, including by smaller organisations that lack the resources of a global pharmaceutical group.

Pharmaceutical companies operate in one of the most regulated, competitive, and politically contested industries in the world – one where the stakes of collaboration and the risks of misalignment are unusually high. If pre-competitive infrastructure can be built here, the argument for building it elsewhere becomes harder to dismiss. 

The logic that produced PAS 2090 – agreeing on how to see the problem before competing on how to solve it – is transferable. It requires patience, institutions willing to invest in shared infrastructure rather than proprietary advantage, and the humility to recognise that a common starting point, however imperfect, is more valuable than a patchwork of incompatible approaches.

System change rarely arrives as a single dramatic breakthrough. More often it emerges from the steady accumulation of the unglamorous: agreed definitions, shared methodologies and common reference points. The standards that attract the least attention are often the ones that shape what becomes possible.

This article is part of InTent’s post-Davos 2026 editorial series, examining the signals and ideas that will shape the next chapter of sustainable business.