Legislation, policy and Cat A’s ‘dirty secret’ – Recolight Circular Lighting Conference (blog part 2)

21st September 2023 – part 2

Moving on to legislation, Maurice Maes from Signify took the delegates through a brief overview of drivers, levers and policy. The  business landscape is affected by a number of forces including industry dynamics, climate change & climate action, geopolitics and protectionism, war & economics and shortage of resources, and existing and upcoming regulations – there are currently 153 regulations applicable to the lighting industry. To combat greenwashing and to simplify the increasingly crowded ‘green/eco label’ market place, the EU is taking measures so that only a select few green labels will be recognised. The proposed Ecodesign for Sustainable Products Regulation particularly stood out as highly ambitious, it is targeted at both consumers and the construction products industry. Measures against green washing must ensure that claims are real and proven, need to drive an ethos of ‘do no specific harm’ and protect and empower consumers (e.g. right to repair).

As you would expect as such as event, CIBSE’s TM66 memorandum (launched in 2021) – Creating a circular economy in the lighting industry – was referred to a number of times. With an overview presentation delivered by Bob Bohannon, Head of Policy and Sustainability at the Lighting Industry Association. Evolving from a checklist to a metric, TM66 – as a Mark Ridler, then of BDP, said – “enables a specifier to use as a tick box list or to put a number against so that minimum standards can be negotiated with a client and then defended in ‘equal and approved’ scenarios”. TM66 delivers clarity and transparency, measurement to show the degree of sustainability, and is transition tool that helps plan and report on the transition and direction of travel.

We also delved into EPDs and LCAs with Whitecroft Lighting, talking about the mix of emissions , currently more operational carbon heavy but with increasing grid decarbonisation this flipping to an  emphasis on embodied carbon. The Embodied Carbon in lighting Memorandum, TM65, was updated in August 2023 and whilst not directly linked to TM66 it has many synergies with it has  .  It was highlighted that TM65.2 does not aim to replace Environmental Product Declarations (EPDs), but allows initial conservative embodied carbon estimations for luminaires and lighting equipment to be made while waiting for EPDs with a full data set to become available. One major issue for lighting m

anufacturers is the complexity of their ranges, compared to steel structures for example. One manufacturer can have 30-40,000 SKUs for one range. Though thankfully it is possible to have one EPD to fit with a range – up to a point – with possibly 14 EPDs to cover 40,000 SKUs.

Following a review of AO’s investment in plastic recycling technology and commitment to producing a high quality recycled plastics with 100% recycled content, the delegates were presented with some interesting new products in true Dragon’s Den style. The 3D printed ‘Clam’ design pendant luminaire took first place over Bell Lighting’s FirestayGeo modular downlight and Elkamet’s biobased light.

Category A Fit Outs – a huge ‘low hanging’ opportunity to reduce waste and drive reuse

A ‘Category A’ or Cat A fit out of the shell and core of a building is a basic operational fit out that provides you with a finished, empty space that is ready for you to move into. A ‘Category B’ or Cat B fit out is the process of bringing all the office design elements together to create a functional workplace complete with flooring and furniture.

Nigel Harvey from Recolight took up the fit-out issue, entitling his presentation ‘Cat A Lighting’s dirty secret’… shockingly up to 100,000 light fittings are removed and/or trashed every week as part of the fit-out process. As he said this is ‘totally inconsistent with a circular economy’. Nigel’s presentation highlighted the following barriers and solutions:

Barriers to change

  • Culture change needed
  • Inertia in many developers and letting agents
  • Some routes to market resistant to change
  • Part L is not a barrier though it might be perceived as such
  • Revenue reduction for some
  • No organisation in supply chain is incentivised to change – all benefit from Cat A – except future generations

Possible solutions

Happening now:

  • Fit out “bays” – to present options
  • Fit out a single floor

Other short term o


  • Leasing: Producer owns and takes back/reuses product
  • Producer takeback pledge. Suppliers commit to takeback and reuse product either prematurely and/or at end of life
  • Recolight Reuse Hub to make used product available
  • Enabling storage of product

Other options:

  • Ban Cat A?
  • Cat A product more standardised, modular and repairable
  • On unit QR code/product passport
  • Easier to de-install
  • Contractors to remove responsibly with incentives
  • AVOID bespoke/unusual dimensions product for Cat A
  • Cat A plus – install fittings most companies will want to keep

The conference was also the official launch of the Recolight Reuse Hub  a lighting digital marketplace. The platform promotes the donation of new and used lighting products and equipment, avoiding waste, reducing recycling, stimulating reuse as well as responding to the climate emergency. More information can be found here https://www.recolight.co.uk/reuse-hub/

We were grateful that Nigel Harvey was also able to be on panel at the recent ASBP Reuse Summit and talk to attendees about the Recolight Reuse Hub there too, underlining the importance of moving away from current predominantly linear practices – particularly with Cat A fitouts – towards more circular strategies and solutions.

The content at the Recolight conference, and in particular Nigel Harvey’s presentation, all pointed to ‘belts and braces’ overhaul of the fit out process to incorporate circular strategies and practices, from the first lease of a building/space and at every refurbishment following that, be it for the same tenant or a new tenant. The justification that prospective tenants need to see how the whole floor could look, is no longer acceptable – and neither is the standard response for a landlord to bank the dilapidations cheque and then strip all the fixtures and fittings out, only for the new occupier to then replace them. How much of the 60 million tonnes of construction and demolition waste per annum in the UK and the 40% of the UK’s carbon emissions that the built environment is responsible for can be attributed to fitout? And compared to shifting practices, design strategies and materials choices in other areas of the industry how easy it is to change how we specify and manage fit outs?

Having spent a little time researching other’s thoughts on this, I came across an article by Kate Paterson, Workplace Architecture Lead, at Ridge and Partners LLP, from which the following is an excerpt:

“…Within the contemporary workplace there are also opportunities for doing away with traditional finishes altogether such as the departure of the previously ubiquitous suspended ceiling…Considered lighting design can also support a move toward Category C with TM66 CIBSE promoting component based light fittings that can be easily repaired and retained. The soon to be launched CEAM (Circular Economy Assessment programme) will also provide guidance to designers on the Category C robustness of the light fittings they specify…”  (Full article here: https://ridge.co.uk/insights/category-c-and-the-office-fit-out/ )

Take a look at the ASBP’s website for more information about reuse across the construction industry https://asbp.org.uk/workstream/reuse-now including our Reuse Now Campaign. Reuse Now aims to increase the reuse of construction products and materials through:

  • Practical focus by exploring supply chain barriers and develop solutions
  • Open dialogue and sharing of knowledge between reuse material donors/recipients and wider ecosystem to enable greater uptake
  • Learn from what others have done to progress quickly (not everyone doing their own research)

For more information please get in touch debbie.ward@asbp.org.uk

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