5.2m UK light fittings removed each year: EPC B retrofit must not add to waste.
London, 27 June 2026
Commercial lighting manufacturer Lumenloop has published an EPC B retrofit waste risk report warning that proposed retrofit work in England and Wales must not turn an existing lighting waste problem into a larger one. The warning follows the Government's June 2026 non-domestic MEES update, which points to EPC B from 2031 for larger private rented buildings 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 when annualised by Lumenloop. Lumenloop says retrofit briefs 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 DESNZ ND-NEED 2025 supporting tables, Energy Performance of Buildings certificate data and Recolight sector evidence. Lumenloop's analysis finds that buildings over 1,000 sq m make up only 6.9% of known-size non-domestic buildings, but account for 59.9% of known electricity use and 70.3% 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," said Paul Simmons, Commercial Director at Lumenloop. "If a retrofit brief 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, controls route or reuse potential has been checked.
For that reason, Lumenloop says commercial lighting retrofit 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 with modular LED gear, replaceable drivers, controls and emergency options before a whole-fitting replacement package is agreed.
The report does not claim that every large building in the DESNZ data is privately rented, or that all EPC-led retrofit will involve lighting 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 brief should ask five questions before strip-out: can the fitting be retained, can the driver be replaced, can the light engine be upgraded, can controls or emergency functions be added, and is there a reuse route 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 and lighting circularity.
About Lumenloop
Lumenloop is a UK commercial lighting manufacturer and supplier of built-to-order LED luminaires for offices, industrial spaces, retail, hospitality, education and refurbishment projects. The company supports project-configured product selection across output, optics, controls, emergency options, mounting and finish requirements.
