TM66 Circular Economy Lighting

What is TM66?

TM66 (Technical Memorandum 66) was published by CIBSE (Chartered Institution of Building Services Engineers) in 2021 as a framework for evaluating the circular economy performance of luminaires. It provides a scoring methodology that assesses a luminaire across multiple criteria including material selection, design for disassembly, component replaceability, recyclability and the availability of spare parts.

The resulting score — expressed as a percentage — gives specifiers, local authorities and sustainability officers a clear, comparable metric for evaluating how well a luminaire aligns with circular economy principles. Products scoring above 75% are generally considered 'excellent' in circular design.

Why Does TM66 Matter?

The lighting industry generates significant waste — millions of luminaires are replaced every year, with many going to landfill because they were not designed for repair or recycling. TM66 directly addresses this by rewarding manufacturers who design products for:

• Longevity — longer operational lifetimes reduce replacement frequency • Repairability — modular construction allows component-level repair rather than whole-unit replacement • Upgradability — replaceable LED modules and drivers enable technology upgrades without discarding the housing • Recyclability — material choices and labelling that facilitate end-of-life material recovery • Reduced environmental impact — lower carbon footprint across the full product lifecycle

Local authorities and public sector organisations are increasingly specifying minimum TM66 scores in tender requirements, making circular design a commercial necessity as well as an environmental imperative.

How is TM66 Scored?

The TM66 assessment evaluates luminaires across five key categories:

1. Material selection — use of recycled content, avoidance of hazardous materials, material passport documentation 2. Design for disassembly — number of fastener types, tool requirements, time to separate components 3. Component replaceability — can the LED module, driver, optic and control gear be independently replaced? 4. Recyclability — can materials be separated into clean recycling streams at end of life? 5. Information provision — availability of maintenance guides, spare parts catalogues and material declarations

Each category is scored and weighted to produce an overall percentage. EOS street lighting products have achieved TM66 excellent ratings through modular construction, standardised connections and comprehensive spare parts availability.

EOS and Circular Design

As a UK manufacturer, EOS is committed to circular economy principles across our product ranges. For us, it starts at the design stage — we always manufacture luminaires that are maintainable or recyclable and offer replacement LED gear trays within both interior and exterior projects.

Packaging also plays a big role. We limit plastic where possible, opting for recyclable materials such as cardboard. For many of our customers, we've become known as the 'retrofit team' — taking on projects that others won't, updating the tech to improve light quality and energy performance while keeping existing luminaire housings in service.

Our specific circular design commitments include:

• Modular luminaire construction with tool-free LED module and driver replacement • Standardised Zhaga-compatible LED modules enabling future technology upgrades • Aluminium housings that are 100% recyclable at end of life • Comprehensive spare parts availability — drivers, modules, optics and lenses available throughout product lifetime • Product passports documenting material composition for end-of-life processing • Extended warranty programmes that support repair-first maintenance strategies

Our street lighting range has achieved TM66 excellent ratings, and we are progressively applying circular design principles across our interior, exterior and industrial ranges. The road to true circularity is long — but we are proud of the steps we have taken, as a relatively small manufacturer, to step away from the 'norm' of the linear model.

The Bigger Picture

Today the industry largely works to a linear system of Design, Build, Use and Dispose. In a circular model, we would work to design out waste and pollution — materials kept in use, and end-of-life products recycled back into the economy.

The pace of change has increased. EU ecodesign regulations now introduce mandatory removability and reparability requirements for lighting products. GACERE (Global Alliance on Circular Economy and Resource Efficiency) was formed to provide global impetus, and the SLL's Circular Economy Checklist and Assessment Method gives specifiers a practical tool for evaluating luminaire circularity.

Ultimately it comes down to us, the manufacturers, to get this right. However, it will take a team effort — clients, contractors, lighting designers, suppliers and the wider lighting community — to ensure that the future of the circular economy evolves. Until then, some simple steps that every project can adopt:

• Think differently at the design stage • Maximise daylight — it's free and produces zero waste • Use controls — put the right light in the right place • Design for the space, not just the standard • Retrofit or upgrade if the equipment is still serviceable