EPC B retrofit push ‘risks adding to lighting waste’

Commercial lighting manufacturer Lumenloop has published an EPC B retrofit waste risk report warning that EPC-led retrofit work in England and Wales ‘must not turn an existing lighting waste problem into a larger one’.
The warning follows the Government’s non-domestic Minimum Energy Efficiency Standards (MEES) update, which proposes EPC B from 2031 for private rented non-domestic buildings over 1,000 square metres in England and Wales, where cost-effective.
Recolight estimates around 100,000 luminaires are already removed from UK buildings every week, equivalent to about 5.2 million fittings a year. Lumenloop says retrofit projects should check repair, reuse and modular upgrade options before strip-out turns an energy-saving job into avoidable waste.
The EPC B retrofit waste risk report brings together Department for Energy Security and Net Zero (DESNZ) Non-domestic National Energy Efficiency Data-Framework (ND-NEED) update 2025 supporting tables, GOV.UK Energy Performance of Buildings Certificates data and Recolight sector evidence.
Lumenloop’s analysis finds that buildings over 1,000 square metres make up only 6.9 per cent of known-size non-domestic buildings, but account for 59.9 per cent of known electricity use and 70.3 per cent of known gas use.
The current legal minimum for privately rented non-domestic buildings in England and Wales remains EPC E unless a valid exemption applies.
The proposed EPC B direction from 2031 still requires secondary legislation, so the report treats the policy as a planning signal rather than live law.
‘EPC B is supposed to cut waste from buildings, not create a new waste mountain above the ceiling grid,’ Lumenloop commercial director Paul Simmons told the Circular Lighting Report.
‘If a retrofit project only asks for lower watts, it can miss the bigger question: can the luminaire be kept in use, repaired or upgraded before the whole fitting is thrown away?’
Lighting is often one of the first upgrade packages considered because it is measurable, visible and relatively straightforward to procure.
That also creates a specification risk: whole-fitting replacement can be agreed before the condition of the body, driver, optics, emergency function, lighting controls or reuse potential has been checked.
For that reason, Lumenloop says commercial lighting upgrades should be treated as a specification decision, not just a purchasing exercise.
Landlords, estate managers, consultants and contractors should check whether existing fittings can be maintained, repaired, reused or upgraded before a whole-fitting replacement package is agreed.
Lighting controls, emergency requirements and maintenance access should be reviewed at the same stage as luminaire selection, rather than added after the retrofit scope has already been priced.
The issue is especially relevant to office refurbishments and wider commercial lighting upgrade programmes, where operating hours, ceiling conditions, controls and emergency provision can all affect the final specification.
The report does not claim that every large building in the DESNZ data is privately rented, or that all EPC-led retrofit will involve LED luminaire replacement.
Its narrower point is that commercial lighting specifications need an early circularity check before strip-out decisions are made.
Lumenloop says every EPC-led lighting upgrade project should ask five questions before strip-out: can the fitting be retained, can the driver be replaced, can the light engine be upgraded, can lighting controls or emergency functions be added, and is there a reuse option for serviceable equipment?
The full report includes charts, regional EPC certificate rankings and source notes for journalists, specifiers and building-services teams covering EPC policy, LED luminaire replacement, reuse options and lighting circularity.
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