Removal of CEE lighting plugs: a turning point for the market

What if this was good news for energy renovation?

Beyond the immediate reactions, this development should above all be read as a strong regulatory signal: the CEE scheme is entering a more demanding phase of maturity, refocused on real impact and additionality.

LED relamping: from innovation to market standard

It must be acknowledged that LED relamping was, for several years, a very effective accelerator of energy savings. The operations were quick to deploy, relatively simple to justify, and often profitable, particularly thanks to the subsidy.

But the situation has changed. In a large proportion of commercial and industrial buildings, LEDs are no longer an innovative solution: they have become the technical standard, sometimes even a prerequisite for maintaining an acceptable level of performance.

However, once a solution becomes almost systematic, the central question of the Energy Savings Certificates (ESC) scheme naturally arises: additionality. In other words, ESCs should finance what would not be done without incentives, and not simply support decisions that have already become “market standard”.

These abuses have undermined the credibility of the system.

Like any incentive mechanism, the Energy Efficiency Certificates (EEC) have sometimes led to opportunistic practices. While not calling into question the serious work of the majority of stakeholders, certain abuses have contributed to undermining trust in the system, in particular:

• inconsistent sizing or oriented towards “prime” rather than “use”;
• files built primarily to increase volume;
• economic models that depend almost exclusively on subsidies;
• strong commercial pressure, sometimes at the expense of overall energy coherence.

In this context, the regulator's choice to tighten the framework is part of a logic of protecting the system: preserving its capacity to finance truly transformative operations, and limiting windfall effects.

What's really changing: the end of a "single-operation" approach

The issue is not just the disappearance of fact sheets. The message is deeper: energy efficiency can no longer be treated as a series of isolated actions (for example “replacing light fixtures”), but as a comprehensive approach, based on use, performance and duration.

In concrete terms, the focus is shifting towards more structured approaches, such as:

• A real technical audit and a detailed analysis of usage;
• Optimizing installed power, schedules, and useful lighting levels;
• The integration of control, regulation and, where relevant, interactions with the HVAC;
• A vision of performance over time (maintenance, deviations, re-parameterization, monitoring);
• A financial structure based on measurable and robust savings, and not solely on the premium.

It is more demanding, but also more consistent with the initial objective of the CEEs: to trigger investments that sustainably change the energy trajectory.

A natural sorting of the market… and an expected increase in skills

This evolution will inevitably create tensions, particularly for players whose model was based on volume and standardization. Some economic models will need to be rethought.

Conversely, organizations capable of thinking in terms of “building” rather than “product” will be strengthened: those that know how to analyze a site as a whole, propose coherent technical scenarios, ensure compliance, and integrate financing into a logic of real performance.

Conclusion: a demanding but transformative reform

The Energy Savings Certificates (CEE) scheme is not intended to subsidize what would be done anyway. It must remain a tool for triggering and accelerating the energy transition, with a level of requirements commensurate with the challenges.

The removal of lighting fact sheets should therefore not be seen as a sanction against a sector, but as a step towards consolidation: greater robustness, greater credibility, and a refocusing on impact.

Abuses have occurred and have impacted the system's balance. This reform can also be an opportunity: to put energy performance back at the center, to value structured and responsible players, and to shift the market from a bonus-based approach to a results-based approach.

Tribune by Léo Perez, Energy Audit Specialist and Business Developer for Clareo Lighting (LinkedIn).