KEY TAKEAWAYS
- Whole-life carbon includes lighting replacements
- Design for serviceability and long life
- Use consistent verified product data
- Prepare now for 2028 disclosure
01The New 2026 Calculation Framework
In May 2026, the European Commission announced a Union framework for calculating life-cycle global warming potential for new buildings. It supports comparable national methods while allowing national detail.
Disclosure is scheduled to begin in 2028 for new buildings over 1,000 square metres and expand to all new buildings in 2030.
02Why Lighting Belongs in Whole-Life Carbon
Lighting contributes through luminaire materials, drivers, controls, installation, maintenance and replacement. Operational electricity remains important, but embodied impacts become more visible as grids decarbonize and equipment efficiency improves.
Design decisions should therefore consider energy and product longevity together.
2026 Industry Impact at a Glance
01 Whole-life carbon includes lighting replacements
Whole-life carbon includes lighting replacements. Include this item in the project or product compliance review.
02 Design for serviceability and long
Design for serviceability and long life. Include this item in the project or product compliance review.
03 Use consistent verified product data
Use consistent verified product data. Include this item in the project or product compliance review.
04 Prepare now for 2028 disclosure
Prepare now for 2028 disclosure. Include this item in the project or product compliance review.
03Service Life and Replacement Cycles
LED modules, drivers and control devices may have different lives. A sealed luminaire that requires full replacement after one component fails can create more material impact than a serviceable system.
Realistic replacement scenarios are essential for credible life-cycle assessment.
04Product Data Challenges
Environmental product declarations and supplier data vary in scope and quality. Teams need consistent boundaries, declared units and evidence for materials, manufacturing and end-of-life assumptions.
Unverified sustainability claims should not be used as calculation substitutes.
2026 Action Matrix
| Responsibility | 2026 Priority | Recommended Action |
|---|---|---|
| Design Team | Interpretation | Translate official requirements into project criteria |
| Manufacturer | Evidence | Maintain verified product and system documentation |
| Owner / Operator | Performance | Commission, monitor and retain handover records |
05Preparing Projects for 2028 and 2030
Start collecting product and replacement data now for projects completing after 2028. Coordinate lighting schedules with the building life-cycle assessor and protect serviceability during value engineering.
A lower-carbon lighting strategy combines efficient operation, durable design and transparent product evidence.