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John, Sales Manager at Low Carbon TecluxJohn, Sales ManagerIndustry News


EPBD Lighting Compliance Guide for Warehouses

Introduction

This EPBD lighting compliance guide for warehouses explains what the EU recast 2024/1275 actually asks from lighting, and which luminaires close the loop without a redesign. The short version: large non-residential buildings must run zoned occupancy plus daylight control tied into building automation, with the scope set by the 290kW and 70kW HVAC thresholds. Warehouses prove it with a DALI-2 linear high bay for warehouses, offices with dimmable downlights, and retail aisles with addressable linear track — one control philosophy in three housings.

FORT-A DALI linear high bay over a warehouse aisle prepared for EPBD audit
Pictured: FORT-A high bays over a warehouse aisle — the housing referenced through this EPBD compliance guide.

Deadlines: EU Text and National Rollout

The recast entered into force on May 28, 2024 with a transposition deadline of May 29, 2026, when every member state must hold national BACS rules. According to the European Commission EPBD overview page, draft national renovation plans were due end of 2025 and final plans end of 2026, so tenders written now already cite the EU dates below even where the local decree is still moving.

DutyEU dateWho is caught
BACS installedDec 31, 2024 / Dec 31, 2029Non-residential, HVAC rated output over 290kW, then over 70kW
Automatic lighting controlDec 31, 2027 / Dec 31, 2029Same stock, suitably zoned with occupancy detection
Netherlands GACSJan 1, 2026 / Jan 1, 2030Dutch rollout of BACS above 290kW, then 70kW
Germany GEG / France BACS decreeJan 2025290kW tier already enforceable in both markets

The 70kW tier is the one that pulls ordinary warehouses, mid-size offices and supermarkets into scope. A building that escapes the 290kW round still lands in the second round, so owners who retrofit now pick luminaires that already carry sensors and reporting instead of plain switched fittings.

Where each country stands

The Commission published its first NBRP assessment in July 2026, covering 16 complete drafts received by June — the Netherlands, Germany, France, Spain and Belgium's Walloon Region among them — with Estonia, Greece and Latvia filing over summer and final plans due December 31, 2026. The table pairs each filing with the BACS vehicle already in force, so a project team reads the audit calendar and the national enforcer in one glance.

MarketDraft NBRPBACS vehicle in forceStatus
NetherlandsMar 19, 2026RVO GACS guide: over 290kW Jan 2026, over 70kW Jan 2030Feedback out
GermanyMay 22, 2026§71a GEG explainer: 290kW duty since Jan 2025Feedback out
FranceApr 21, 2026French BACS guide: 290kW duty since Jan 2025Feedback out
SpainDec 29, 2025EU tiers via transpositionFeedback out
Belgium (Wallonia)Dec 23, 2025EU tiers via regional codeFeedback out
Estonia, Greece, LatviaSummer 2026EU tiers via transpositionFeedback in Q3
Remaining states—National rules with May 2026 transpositionFinals due Dec 2026

Filing is step one; the audit needs three physical actions per zone, in this order:

  • Mounting — one combined occupancy plus daylight head per zone at the coverage height its datasheet states, viewing the task plane rather than the window; the REHVA rooms earned their Class A only after sensor re-placement.
  • Calibration — hold the task plane at the maintained illuminance EN 12464-1 assigns to the task, and log the dimming curve against daylight hours so the auditor sees control, not just hardware.
  • Proof — run the LENI math per EN 15193-1, so the occupancy (F_O), daylight (F_D) and constant-illuminance (F_C) layers each bank a metered saving in the audit file.

What Lighting Must Show an Auditor

Article 13 names built-in lighting a technical building system, and the lighting control system that drives it counts as a BACS. The mandated BACS must continuously monitor, log, analyse and adjust energy use, benchmark efficiency, detect losses and talk to other systems. For lighting that cashes out as three checkable lines per zone, graded under EN ISO 52120-1 with Class B as the floor and Class A as the high-performance grade.

  • Zoned occupancy — automatic presence control per zone, not one contactor for a whole floor.
  • Daylight response — continuous dimming against ambient lux, not a timer schedule alone.
  • Energy record — per-point metering and fault history the BMS can read at audit time.

Presence alone does not pass: LightingEurope notes that occupancy detection without dimming, zoning and data still stalls below the required grade. That is why this guide pairs every zone with a dimmable driver plus a combined occupancy and daylight head, and the DiiA DALI data specifications for Parts 251-253 define the per-driver energy and diagnostics dataset auditors expect on wired jobs.

Class D to Class A in lighting terms

Under EN ISO 52120-1 the four classes step from D (manual, non-energy-efficient — no longer permitted in new builds) to A (high performance with energy management). A REHVA measurement campaign in three seminar rooms mapped what each step means for lighting: Class C is manual on/off without dimming, Class B adds automatic off on presence and daylight, and Class A adds constant-light closed-loop control on top. The campaign also showed the Class A gain hinges on commissioning details such as sensor placement — hardware buys the grade, tuning keeps it. The per-point metering auditors ask for rides on the management functions behind the grade: D4i Parts 252 and 253 are the enabler there, not the grade itself. National checks calibrate the same scale — the Dutch RVO asks existing stock for Class C overall with Class B management functions, and newbuild for Class B with Class A management functions.

ClassLabelWhat the lighting zone does
DNon-energy-efficientManual switching only; existing stock must be retrofitted, new builds may not use it
CStandard (reference)Manual on/off without dimming — the measured baseline
BAdvanced (EPBD floor)Manual on plus automatic off on presence and daylight sensing
AHigh performanceClass B functions plus constant-light control, with energy and diagnostics data (D4i Parts 252/253 as enabler) available to the BMS

Offices: Downlights That Hold Comfort and Grade

Open offices fail audits on glare and granularity at once: one panel per large zone with no sensor. The fix is smaller DALI zones of anti-glare downlights for offices with presence plus daylight heads, so perimeter rows dim against windows while corridors hold on sensor. The GLOW-D DL01 family behind this pattern runs 10-30W at up to 150lm/W with Ra90, reaching 4300lm through 105-200mm cutouts, UGR22 comfort optics in 38 and 60 degree beams, and 0-10V or DALI dimming across 3 to 8 inch housings — efficacy and comfort in one ordering line.

GLOW-D DL01 downlights over an apparel retail floor showing zoned rows
Pictured: GLOW-D DL01 downlights — UGR22 Ra90 zones that dim per perimeter row.

Warehouses: High Bays That Carry the Audit

High-bay aisles are the largest single lighting load in most logistics buildings, so the auditor starts there. FORT-A answers as an 80-200W linear high bay at up to 170lm/W, IP65 and IK08 with tempered glass and 50 by 100 degree aisle optics, DALI-2 dimming with microwave or PIR plus daylight sensor options on a Zhaga-ready position. The same housing serves Class B jobs on switched DALI and Class A tenders on D4i reporting drivers, which keeps one optic and one mount across both grades.

FORT-A linear high bay with aisle optics and sensor option for warehouse EPBD zones
Pictured: FORT-A linear high bay — 80-200W DALI housing with aisle optics for sensor zones.

Retail Aisles: Addressable Linear Track

Supermarket and mall aisles need per-bay scenes rather than whole-floor switching, which is where six-wire DALI track linear earns its place beside high bays and downlights. TRON-WD runs 22-50W per length at up to 170lm/W on DALI DT6 brightness with DIP CCT presets, so each bay dims and reports while colour stays preset per rollout. Start from the retail lighting layers for sales floors to split ambient, accent and window rows, then put this linear on the ambient rows where EPBD zoning is checked first.

TRON-WD DALI linear track light for retail aisle EPBD zoning
Pictured: TRON-WD linear track — addressable DALI bays for retail aisle scenes.

How This Guide Differs From the Wired Deep Dive

Readers coming from our DALI pages sometimes ask which one to follow. The split is deliberate: one page picks the luminaire per building type, the other opens the driver.

QuestionThis EPBD guideDALI-2 D4i deep dive
Main decisionWhich fitting per zone: downlight, high bay, linear trackWhich driver dataset: Parts 250-253, Zhaga sockets
DeadlinesEU plus NL, DE and FR national datesWiring scope for Class A reporting
ProofFORT-A plus DL01 plus TRON-WD across three scenesFORT-A as single wired audit example — see the wired DALI-2 D4i compliance path

FAQ

Non-residential buildings above the HVAC power tiers. The EU text sets BACS above 290kW from end of 2024 and above 70kW from end of 2029, with automatic lighting control one step behind at 2027 and 2029. Warehouses, offices and supermarkets in the 70kW band are the bulk of second-round projects, and this guide targets exactly that stock.

No, occupancy alone still leaves the zone below grade. Auditors also check daylight-linked dimming per zone plus an energy record the BMS can read. Every zone in this guide pairs a presence head with a photocell and a dimmable DALI driver, so one sensor position closes both functions.

Specify a DALI dimmable Ra90 downlight with UGR22 optics. GLOW-D DL01 covers 10-30W up to 4300lm at 150lm/W across 105-200mm cutouts, so perimeter rows and corridors zone separately without changing the ceiling grid. The FORT-A high bay in this same guide covers the warehouse next door.

Specify a DALI linear high bay with aisle optics and a sensor position. FORT-A spans 80-200W to 34000lm at 170lm/W, IP65 IK08, 50 by 100 degrees for rack aisles, with D4i reporting drivers where the tender asks for per-point energy. Offices in the same project take the DL01 downlight above.

Yes, the EU sets the floor and capitals set the calendar. The Netherlands enforces GACS from January 2026 above 290kW and 2030 above 70kW, while German and French 290kW duties already bit in January 2025. Always confirm the local decree at order time; the luminaire scope in this guide satisfies all three.

Class B means the zone switches itself, Class A means it also dims itself and reports. Class B pairs manual on with automatic off on presence and daylight, enough for the EPBD floor. Class A adds constant-light control plus per-driver energy and diagnostics to the BMS — the FORT-A high bay on D4i drivers and the DL01 downlight on DALI in this guide.

Most of our project markets filed early: the 16 covered drafts include the Netherlands, Germany, France, Spain and Wallonia. Estonia, Greece and Latvia followed over summer 2026, and every final plan is due December 31, 2026. One luminaire scope covers all rows because the EU power tiers behind them are identical.

Conclusion

Pick the zone first and the protocol second: downlight rows for offices, linear high bays for warehouse aisles, addressable linear track for retail rows, each with occupancy plus daylight and a record the BMS can read — the comparison above holds the wired dataset behind this option. Where ceilings must stay closed and no new bus can be pulled, take the wireless branch instead: the Bluetooth NLC buyer rules for wireless retrofits keep DALI drivers behind a gateway.

Lighting becomes audit evidence when each zone shows presence control, daylight response and a readable energy record — not when the building simply swaps to LED. That is why one sensor position plus one dimmable driver per zone beats whole-floor switching in every EPBD check.

eu.bac, EPBD transposition guidelines

Sources

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