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

What if this were good news for energy renovation?
The removal of the BAT-EQ-127, IND-BA-116, and BAR-EQ-110 forms caught many stakeholders off guard. For some, it is a brutal challenge to a widely used lever; for others, a decision that is difficult to understand given the persistent renovation needs. Beyond the immediate reactions, this development should above all be read as a strong regulatory signal: the CEE scheme is entering a maturity phase, more demanding, refocused on real impact and additionality.

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LED relamping: from innovation to market standard

It must be acknowledged: LED relamping was, for several years, a very effective accelerator of energy savings. 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 part of tertiary and industrial buildings, LED is no longer an innovative solution: it has become the technical standard, sometimes even a prerequisite to maintaining an acceptable level of performance.

Yet, as soon as a solution becomes quasi-systematic, the central question of the CEE scheme naturally arises: additionality. In other words, CEEs must finance what would not happen without an incentive, and not accompany decisions that have already become "market standard."

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Abuses that have undermined the credibility of the scheme

Like any incentive mechanism, the CEE has given rise to opportunistic practices. Without calling into question the serious work of the majority of stakeholders, certain abuses have contributed to undermining confidence in the system, notably:

• Incoherent sizing oriented toward "subsidy" rather than "usage";
• Files built primarily to generate volume;
• Economic models depending 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 scheme: preserving its capacity to finance truly transformational operations, and limiting windfall effects.

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

The issue is not solely the disappearance of forms. The message is deeper: energy efficiency can no longer be treated as a succession of isolated actions (for example "replacing luminaires"), but as a holistic approach, based on usage, performance, and duration.

In practice, value is shifting toward more structured approaches, such as:

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

It is more demanding, but also more consistent with the original objective of the CEE: to trigger investments that durably change the energy trajectory.

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A natural market selection… and an expected rise in competence

This development will inevitably create tensions, particularly for stakeholders whose model was based on a logic of volume and standardization. Certain economic models will need to be rethought.

Conversely, organizations capable of thinking "building" rather than "product" will be strengthened: those that know how to analyze a site as a whole, propose coherent technical scenarios, secure compliance, and embed financing within a logic of real performance.

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Conclusion: a demanding but structuring reform

The CEE scheme is not intended to subsidize what would be carried out regardless. It must remain a trigger tool and an accelerator of the energy transition, with a level of demand commensurate with the challenges.

The removal of the lighting forms should therefore not be read as a sanction on a sector, but as a consolidation step: greater robustness, greater credibility, and a refocus on impact.

« Abuses did exist and weighed on the balance of the system. This reform can also be an opportunity: to put energy performance back at the center, to value structured and responsible stakeholders, and to move the market from a subsidy logic to a results-driven logic. »

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