GreenLight Alliance: Code of Practice for luminaire remanufacture

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 Replacing outdated lighting components with today’s technology, and re-investing cost savings derived from reusing components means that remanufactured products can be better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!

Remanufacture routes and considerations:

Original Luminaire Manufacturer (OEM) Remanufacture 

• Ideally there should be planned remanufacture stages from initial design stage.

• May be able to build this into a commercial agreement with customer.

• Should hold valid design documents for the product and thus able to accelerate reverse engineering process.

• If remanufactured to original specification, they can retain original product designation.

• May have spares / components available if this is an active SKU.

• Must be aware of regulatory changes since original build and have compliance methodology to reflect that. 

Independent Remanufacturer 

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

• Third party Original Equipment Reproduction businesses (OERs) develop a specialism for remanufacture, meaning they can assess and remanufacture a variety of products.

• Third party OERs may be working at lower volumes or with greater variety of products than OEMs would be.

• OERs may develop specialisms for certain types of product or even specific products.

• OERs may offer remanufacturer as a service to the OEM (i.e., the end user may not consult directly with the OER, but through the OEM)

• OERs often in contact with a client for a specific site remanufacturing project, where there may be multiple products from different manufacturers. A single OER may be better able to deal with this situation.

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.

• Reduction in transportation of fittings is likely to reduce cost, carbon and pollution.

• Sub-assemblies may be selected or designed to suit client needs and fitting specifics.

• Assessment of fitting’s condition integral to strategy. Contingency for deeper repair/replacement.

• Prior compliance assessment should be done on a representative sample fitting. Final testing on all units essential. 

• BS 60598 Annex Q electrical safety tests cannot be conducted without suitable mobile test facilities.

User/owner upgrade

• Clarity where liability rests. 

• Not likely to receive warranty.

• Installer competence level.

• Is the luminaire accurately assessed for suitability with the off-the-shelf retrofit product?

Buy back schemes

• An effective way for manufacturers to prove their commitment and trust in a product.

• Should result in an incentive for manufacturers to remanufacture and re-sell products.

• Buyback rather than remanufacturing for a site can overcome issues with lighting downtime and turnaround time for the remanufacturer.

• Manufacturers need to keep good analysis on the circular outcomes of these processes, because buying-back products isn’t the desired outcome, but a tool.

www.egglighting.com

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:

• Remanufacturing – industrial process in which a product is produced from objects that are waste, products or components and in which at least one change is made to the product that affects the safety, performance, purpose, or type of the product typically placed on the market with a commercial guarantee.

• Upgrading – enhancing functionality, performance, capacity, or aesthetics of a product.

• Refurbishment – preparing or modifying an object that is waste or a product to restore its performance or functionality within the intended use, range of performance and maintenance originally conceived at the design stage, or to meet applicable technical standards or regulatory requirements, with the result of making a fully functional product.

• Maintenance – an action conducted to keep a product in a condition where it is able to function as required.

• Repair – returning a defective product or waste to a condition where it fulfils its intended use.