Retrofit rules risk adding 5 million bulbs to landfill each year

The UK generates 5.2 million tonnes of lighting waste every year, and the government’s own energy efficiency programme could make that number worse. A report from Lumenloop, a lighting industry research group, warns that the push to meet Minimum Energy Efficiency Standards (MEES) is driving landlords and homeowners to rip out perfectly good LED fittings and replace them with new ones, simply to tick a compliance box.

As reported by markets.businessinsider.com, the Lumenloop report found that the current retrofit frenzy is adding to an already strained waste system. The data is stark: the UK already discards enough lighting waste each year to fill Wembley Stadium. If every rental property in England upgrades its lighting to meet the 2028 EPC C deadline, the report estimates an extra 15 million functional LED panels and downlights will be binned.

Why the rules create waste

MEES requires private rented properties to have an EPC rating of C or above by 2028. Lighting efficiency is a cheap, quick way to boost a score, a single LED downlight can add up to 4 points on the EPC scale. But the regulations don’t distinguish between a 15-year-old halogen bulb and a five-year-old LED that still works. Landlords, facing a hard deadline and a shortage of accredited assessors, are opting for wholesale replacements. One installer told Axiom he’d pulled out 120 working LED panels from a single block of flats in Manchester last month. All went to a skip.

The catch is that many of these fixtures are designed to last 25,000 hours, roughly 15 years of typical use. Replacing them after five or six years is wasteful and economically irrational. A new LED downlight costs £8-15; disposal adds £2-4 per unit in skip hire and landfill tax. For a 50-unit block, that’s £500-750 in unnecessary cost, passed straight to the tenant via higher rent.

What a typical 3-bed semi costs

For a standard 3-bed semi, a full lighting retrofit, replacing 15-20 fittings with EPC-friendly LEDs, runs £200-400 in materials and labour. But the hidden cost is the waste. If the old fittings are still functional, you’re paying to throw away something that could last another decade. The Energy Saving Trust estimates that lighting accounts for 15% of a typical household’s electricity bill. Switching to LEDs saves about £35 a year. But replacing working LEDs with new ones saves nothing, the efficiency gain is already captured.

Ofgem’s latest data shows the average household spent £1,104 on electricity in 2024. Lighting’s share is roughly £165. A working LED already delivers the bulk of the saving; swapping it for a new model might trim another £2-3 a year. That’s a payback period of over 50 years, far longer than the fixture’s own lifespan.

What homeowners should do

The first step is to audit what you already have. If your existing lights are LEDs and the EPC assessor says they’re fine, don’t replace them. If you need to upgrade for a sale or rental deadline, specify in the contract that the installer must reuse or recycle all removed fittings. Several specialist recycling firms now take LED panels and downlights, check with your local council’s waste authority. The cost of recycling is typically £1-2 per unit, compared to £4-6 for landfill.

If you’re a landlord, push back on blanket replacements. Ask your contractor to produce a waste minimisation plan. The Green Building Council’s retrofit guidance recommends a ‘fabric first, reuse second’ approach. Lighting is the easiest place to start: keep what works, upgrade only what’s broken or genuinely inefficient.

Households planning a full retrofit should act before the 2028 rush. The current shortage of qualified assessors and installers means prices are rising, and so is the pressure to cut corners. Book an EPC assessment now, and ask the assessor to specify which fittings must be replaced and which can stay. That single conversation could keep 10-15 bulbs out of landfill, and save you £100-200 in unnecessary replacement costs.