EU Smart Lighting "Mandatory Threshold" Takes Effect in May! Chinese Luminaire Exports Face a Major New Test
The revised EU Energy Performance of Buildings Directive (EPBD) was revised and published in May 2024. According to the regulations, all EU member states must transpose the directive into national law by May 29, 2026—this means that from May 2026 onwards, the revised EPBD will officially enter the full implementation phase.
For Chinese lighting export enterprises, this is the first and most urgent compliance test faced this year. The mandatory requirements brought by the EPBD directly overturn the past logic that "luminaires can enter the market as long as individual products meet standards".
The core requirements of the new regulation are extremely clear:
All newly constructed commercial buildings in the EU must mandatorily install automatic lighting control systems and building automation systems. This clause directly transforms smart lighting from a past value-added optional feature into a mandatory standard for new commercial projects. Specifically:
1 Products are no longer isolated lighting units; they must possess core attributes of connectivity and integrability, seamlessly accessing the building's overall intelligent management system to achieve dynamic dimming based on occupancy and natural light, energy consumption monitoring, and intelligent control; 2 At the technical level, standardized adaptation must be completed, focusing on interfacing with the EU's "Smart Readiness Indicator" (SRI) and global communication protocols such as Matter, ensuring product interoperability; 3 The driver end must meet the mandatory requirements of D4i Gen 2. It must not only have basic DALI dimming functionality but also comply with DALI Part 250–253 standards for energy consumption metering and fault diagnosis capabilities. Additionally, the driver must be installed independently, use pluggable wiring terminals, and must not share a heat dissipation path with the LED module. For the large number of domestic enterprises that still mainly produce traditional lighting products or simple smart products, this means: if they cannot complete the intelligent upgrade of their products and adapt to system integration, even if their luminous efficacy and energy efficiency indicators fully meet the standards, they will not be able to enter the core market of new commercial buildings in the EU, facing the direct risk of being excluded from mainstream procurement lists. If the EPBD sets the red line for intelligent access,thenthe "Ecodesign for Sustainable Products Regulation" (ESPR), which officially came into effect on July 18, 2024,reshapes the underlying logic of product compliance from a top-level design perspective.The ESPR expands the regulatory boundary from energy-related products to almost all physical goods, upgrading the evaluation criteria from single energy efficiency parameters to the environmental impact and sustainability performance of the product throughout its entire life cycle. The "dual regulation" system composed of EPBD and ESPR jointly pushes Chinese lighting export enterprises to a critical node of comprehensive capability upgrade. Customs data for the first quarter of 2026 shows that China's total lighting product exports amounted to approximately USD 11.4 billion, a year-on-year (YoY) decline of 3.5%. Among these, exports to the United States declined significantly, while exports to the EU market bucked the trend with an 8% growth. The survey from the Hong Kong Spring Lighting Fair, which concluded on April 23, also indicates that nearly half of the respondents expect sales to rise in the next two years, and consumers are willing to pay a premium of nearly 30% for smart lighting. It is evident that the European market is not shrinking, but rather raising its entry barriers. Companies that take the lead in completing upgrades towards intelligence, standardization, and green practices are expected to gain a larger market share in the new round of industry reshuffling. Source: China Lighting Electrical Magazine