It could be but that is not its purpose in life. This post was inspired by question, "why not make PDS exporting (or conversion from Geotiff) available from the NASA AMES Stereo Pipeline." This was my answer. Please note this is IMHO - please feel free to disagree.
So I assume there are many PDS3 (and now some PDS4) writers out there. I actually don't know of a robust GeoTiff to PDS image converter. In general, I view the PDS (3 or 4) format as really an "archival" format and not necessarily a good format to support interoperability between applications. Okay so what's the difference? Archive formats are meant to be "simple" to use and should have verbose labels to access the data for years into the future. Sounds great - what's the problem? In particular, PDS archives can have metadata spread across multiple files which describe the mission, image label particulars, the map projection equations (which may not be typical equations, if even map projected at all), etc., which makes a single image file less self-contained. Thus not only should a PDS *.IMG (image with label) be created, but to be a valid PDS archive, there should also be other informational files created in a structured set of directories. When GeoTiffs are used for archives (more common for Earth data sets), they actually have the same metadata problem, which is usually solved by using an FGDC/ISO metadata file sitting directly next to the GeoTiff (extension *.tif.xml).
Okay - I don't care about metadata, I just want to write out a PDS *.IMG format. Above, I stated there are probably dozen of PDS writers out there. The main reason there are so many is because the folks writing these files must target their labels for their particular mission. It would be a challenge to create a generic PDS label creation/conversion solution. Many portions of the required metadata cannot be 100% automated (whether PDS or FGDC metadata). For example for PDS, there are many keywords that the user should supply that would need to be (manually) defined during conversion (e.g. PRODUCED_ID, PRODUCER_FULL_NAME, INSTRUMENT_HOST_NAME, etc.). Check out any *.lbl from here.
All that said, both ISIS3 and VICAR can convert to a "generic" PDS v3 label, but it will not be a fully archive-able PDS label. To help with the mission particulars, you will notice ISIS3 has a unique PDS export routine for each instrument (when that instrument is supported for PDS export, e.g. lrocnac2pds, lrowac2pds, mrf2pds - https://isis.astrogeology.usgs.gov/Application/index.html#Lunar_Orbiter ).
Anyway, I am happy to share a very simple (hacky/brute force) gdal2PDS (v3) Python writer but it would need to be highly tweaked depending on the mission you are supporting. And I currently only support a couple projections as used by the LMMP project. Did I say it was very hacky -- use with caution: http://github.com/USGS-Astrogeology/GDAL_scripts/tree/master/gdal2ISIS3
Could a generic PDS3 writer be added to GDAL - yes. But PDS3 is slowly getting supplanted by PDS4 so that would need to be added too. PDS4 is XML based which can complicate simple writers. There are plans to add in a PDS4 reader to GDAL once the format stabilizes. A reader should be much more tangible than a generic writer (for map projected products at least). Heck, we could even support a "raw" Geotiff with a PDS 3 or 4 label pointing inside at the pixels, but raw Tiffs lose many benefits like tiles and compression capabilities.
lots more information about PDS4: http://sbndev.astro.umd.edu/wiki/PDS4_Data_Structures