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GreenLight Alliance: Code of Practice for luminaire remanufacture

21st September 2022

Published in arc magazine issue 130 (issuu) (web)

Tom Ruddell, Lead Remanufacture Engineer at EGG Lighting, provides guidance on how a code of practice for the remanufacture of luminaires can help the lighting industry shift to a circular economy.

Remanufacture is an industrial process that creates a new product from used and new products or parts/components. Lighting equipment has always been changed, modified, fixed, converted and everything in-between. Yet while other industries such as electronics, automotive and others have well-established and well-defined circular economy processes built into their industries, these models are still at the periphery of the lighting industry.

As the lighting industry starts offering not only upgradeable fittings but developing the capabilities to do so alongside traditional manufacturing models, we will need generally understood terminology and processes to successfully bridge the gap to the circular economy.

At the end of 2020, a group of lighting industry professionals formed around the idea of writing a standard that would do just that – and offer the industry a general process for the remanufacture of luminaires, building on existing best practice in the BS 8887 family of standards.

Motivations

Why are we so enthusiastic about remanufacture and circular processes? In the context of a climate crisis remanufacture is a critical technique – it can reduce cost, reduce waste, reduce carbon, and improve performance – all at the same time.

Luminaires are complex assemblies and cleaning, shredding, and recycling them is energy and resource-intensive – so keeping components in their finished condition can save a lot of waste and carbon. Take the example of a cast aluminium housing – it’s clear that blasting and re-coating will entail less embodied carbon than making the component again from scratch. Remanufacture also tends to shorten supply chains – shifting the focus away from importing finished goods and thereby reducing transport emissions.

Remanufacture also goes hand-in-hand with technology upgrades, which is crucial in the lighting industry. Replacing outdated lighting components with today’s technology, and re-investing cost savings derived from reusing components means that remanufactured products can be better than new. This means remanufacture can be a force for reducing energy costs, improving lighting quality and delivering connected lighting – while offering an alternative to scrapping entire lighting systems and starting again.

Variety in all ways

Around 40,000 tonnes of lighting equipment is placed on the UK market alone each year – a massive amount. The variety therein is so vast that no single approach could encompass them all – so the committee has taken great care to ensure the standard will be as widely applicable as possible. We’ve considered an exhausting range of remanufacture scenarios – from heritage products to barely-used LED fittings (for example Class A fit-outs or trade shows), warranty returns, manufacturing rejects, emergency conversions, damaged products, lighting with failed control systems, lighting installations needing to adapt to a change-of-use – and the list goes on.

The committee has also been careful to consider different remanufacture models. While remanufacture is traditionally conducted at an industrial facility, we recognise that lighting can and will be remanufactured wholly or partly ‘on-site’ or even in temporary or mobile workshops. The same goes for business models – ranging from OEMs remanufacturing own-brand fittings inhouse or through third party operators to independent remanufacturers – we may soon see the development of markets for remanufactured and used components. Being open to and aware of all these options will encourage innovative circular approaches, specific to the needs of our industry.

Compliance

Compliance is a key consideration at all stages of remanufacture and is certainly the most-discussed topic by the committee. How do you ensure a remanufactured luminaire is ‘compliant’ and suitable for CE or UKCA marking? What is the implication of remanufacturing on-site? How do you deal with variety in product condition? These are the challenges that remanufacturers will need to build into their processes, considering the use-case, known (and unknown) product history, the quantity for remanufacturing and other factors to determine their approach.

Some of the considerations dealt with by the standard include luminaires where manufacturer identification is integral to the construction, assessing compliance changes since the equipment was originally placed on the market, non-destructive testing, hazardous materials that may be present in the luminaire and compliance of reused components.

In many cases these are not simple discussions, and the objective has been to provide a framework of guidance now, which won’t prevent the industry from innovating and developing new circular economy processes and methods in the future.

About the Standard

This process standard is within the “8887” family which already has a kitemark programme and a history of use in other industries. It is not a design standard and won’t instruct “what” to do, only guidance on “how” to go about doing it.

It will probably initially be published as a code of practice, allowing the industry to use the process while giving space for learning and improvement as the state of the art develops. This standard has been in drafting for about a year and a half and will soon begin the process of formatting and editorial, supported by an expert from the BSi, to dot the i’s and cross the t’s. Committees overseeing relevant and related standards will be contacted for comment before the standard will be made available for public comment.

We hope this will play a part in helping the lighting industry offer robust and high-quality remanufacturing models and embrace a common language. Anyone interested in sharing ideas or becoming involved in this voluntary work should contact the Committee Manager Sarah Kelly (Sarah.Kelly@bsigroup.com). Now, over to you!

Further notes on Remanufacture routes and considerations:

(I sent this as loose notes in an email and I was surprised to see it had been published alongside the edited article. Lesson: be specific with editors because you can't un-publish)

Original Luminaire Manufacturer (OEM) Remanufacture

Independent Remanufacturer

In many instances original manufacturers may not be equipped or prepared to remanufacture their own fittings.

On site intervention

Feasibility of this route likely to be dependent on factors relating to the site.

Products specifically designed for on-site remanufacture will facilitate this approach. Many products, however, will not be suitable.

User/owner upgrade

Buy back schemes

Definitions

The EU’s ESPR (Ecodesign for Sustainable Products Regulation) definitions give an interesting preview of how EU policy makers see this topic. It is a proposal for a regulation establishing a framework for setting Ecodesign requirements for sustainable products and repealing Directive 2009/125/EC. A consultation period allows specific industries to make comment potentially for changes to better suit theirs e.g., lighting. In it are several helpful definitions:

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