At a glance

DocumentWhat it isWhat you getLimit
CIBSE TM65 (method from 2021)An estimate of the embodied carbon of building services products with no EPDConservative estimate from materials, processes and transportNot an EPD or a life cycle assessment (CIBSE)
CIBSE TM65.2 (July 2023)The lighting version: calculation methods, reduction actions, low-carbon material guidanceEstimate for a luminaire or its parts“Does not aim to replace” EPDs (CIBSE)
CIBSE TM66 (October 2021)Circular economy in the lighting industry: checklist, assessment method, examplesA circularity picture, not a carbon numberSays nothing about carbon on its own
CEAM-Make, CEAM-SpecifyTM66's digital tools: Make for manufacturers, Specify as a quick comparison for specifiersCEAM-Make gives a rating from 0 to 4 (CIBSE Journal, 2022)Self-assessed unless someone verifies it
EPDA third-party verified declaration of life-cycle impacts to EN 15804+A2Verified impacts for a stated product and unitRare for a one-off decorative piece
What to ask forMaterials list, method and boundary, recycled content evidence, replaceability, spares, take-backA written supplier statementNo figure is better than a figure with no method

From CIBSE's own listings and two CIBSE Journal articles (2022 and 2023), read 7 November 2026. TM65.2 and TM66 themselves are paid documents and were not read.

TM65, TM65.2, TM66 and EPDs: what each one is

Four documents get mixed up when a client asks for “the carbon figure” for a chandelier or a pendant. They answer different questions, and a decorative or bespoke luminaire may have none of them. Knowing which is which lets you ask a precise question and read the answer for what it is.

DocumentWhat it measuresWho it is forWhat it is not
TM65Embodied carbon of products made of different parts that lack an EPD. CIBSE says it gives a conservative estimate and is best suited to metal and plastic products with complex supply chains.Engineers and manufacturersNot an EPD and not a life cycle assessment; not 100% accurate (CIBSE).
TM65.2The same approach applied to lighting. CIBSE lists calculation methods (the TM65 tools, a manufacturer form, input assumptions), actions to reduce embodied carbon and guidance on low-carbon materials.Lighting designers, specifiers, lighting engineers and manufacturersCIBSE: it “does not aim to replace Environmental Product Declarations”.
TM66How circular a luminaire is: repairable, upgradable, recoverable. It sets out the principles with a checklist, a method for assessing circular performance and examples.The whole lighting sectorA circularity method. Not a carbon calculation.
CEAM-Make and CEAM-SpecifyTM66's two tools. Make is the full manufacturer tool (66 questions, per the 2022 CIBSE Journal module); Specify is a quicker triage tool (24 questions) for comparing products. CEAM-Make gives a rating from 0 to 4; the module does not say how Specify reports.Make: manufacturers. Specify: designers and specifiersA score from the supplier's own answers unless an independent body has checked it.
EPDLife-cycle impacts for a defined product and unit, verified by a third party to a stated standard (EN 15804+A2 for construction products).Anyone comparing productsUsually available for a catalogue product, not a one-off. See the EPD sheet.

The studio does not hold carbon or circularity data for any luminaire, and this sheet gives none. It tells you what to ask a supplier or partner workshop to provide.

What each carbon and circularity document tells you about a luminaireThree columns. TM65.2 gives an estimate of embodied carbon from materials. An environmental product declaration is a verified report of impacts. TM66 and its tools score how repairable and recoverable a luminaire is.TM65.2 EstimateThe questionHow much carbonis in the materials?What you getA conservative estimatefrom a materials listNot a verified declarationEPD Verified reportThe questionWhat are the product'slife-cycle impacts?What you getThird-party verifiedto a stated rule setRare for one-off piecesTM66 Circularity scoreThe questionCan it be repaired,reused and recovered?What you getQuestions on design,materials and take-backSays nothing on carbonUse them together; none of them replaces the supplier's own disclosure
The question each document answers. Schematic. Original drawing by Make Bespoke Studio.

Reading the numbers without being misled

An estimate is not a declaration. TM65 and TM65.2 give a conservative estimate from a materials list. An EPD is a verified statement to a rule set. Do not set one against the other as if they were the same kind of number; ask which method each figure comes from, who calculated it, and what it covers. The CIBSE Journal’s 2023 article on TM65.2 says it is not meant to replicate or replace a full life cycle assessment, though its results are closer to one than TM65’s generic data.

Known limits of the method. CIBSE’s TM65 page lists some: the recycled-content input does not currently affect the calculation, some materials (zinc alloy, for example) are missing from the database and the closest material is substituted and noted, the default factors come from a database that is being replaced, and replacement assumptions default to 10 per cent if left blank. The CIBSE Journal article on TM65.2 says aluminium has separate coefficients for 100 per cent recycled and 100 per cent virgin material. We have not read TM65.2 itself, so ask the supplier which version of the tool and which coefficients were used.

Carbon and circularity are different questions. The CIBSE Journal’s module says low embodied carbon does not guarantee circularity, and a circular product is not automatically low-carbon, although the two are linked. It also warns that manufacturers may greenwash products, so claims need checking, and that LED life depends heavily on design quality, heat management and driver electronics. Integrated LED units usually have to be replaced whole when one component fails, which limits reuse.

A bespoke piece may have no data at all. A one-off made for a project is unlikely to have an EPD of its own (see how to read an EPD). That is not a reason to skip the question. A materials list with masses, a stated method and honest gaps are worth more than a single figure with no basis.

Where carbon and circularity sit in a decorative luminaire

These are the places where a decorative luminaire’s carbon and circularity are decided. They are a guide to what to ask, not a ranking: we hold no figures to order them, and the weight of each depends on the design. The first five rows follow the inputs CIBSE lists for TM65 (materials, manufacturing, sourcing, transport, service life and replacement).

PartWhy it mattersAsk
Metal frame and armsUsually the largest mass in a decorative luminaire. Alloy and recycled content change the answer (TM65.2 treats recycled and virgin aluminium separately).Alloy, mass, recycled content and evidence of it; where the metal was sourced.
GlassHand-made glass is shaped and annealed in heated furnaces, and breakage in transit means making a part twice. We hold no figure for either.Glass mass, how it is protected in transit, whether replacement parts are held.
Light source and driverElectronics have their own footprint and fail sooner than metal or glass. Whether they can be replaced decides whether the whole fitting is scrapped.Is each replaceable with common tools? Model, availability, service life assumed. See the Ecodesign sheet.
Finish and platingPlating, gilding and coatings add process steps and may complicate recycling. We hold no source for the effect.Finish type; whether it can be refinished instead of replaced.
Packaging and transportCrates, foam and shipping distance count in the calculation. TM65 asks for transport distances.Packaging material, reusability, where made and shipped.
Spares, repair, take-backDecide whether the fitting is repaired or replaced when something fails (TM66).Spares held and for how long; repair instructions; return route for refurbishment.
Where to ask about carbon and circularity on a decorative luminaireA schematic chandelier with six numbered question points: metal frame, glass, light source and driver, finish, packaging and transport, spares and take-back.1Metal frame and arms2Glass type and weight3Light source, driver4Finish and plating5Packaging, transport6Spares and take-back
Six places to ask about on a decorative luminaire. Schematic, not to scale. Original drawing by Make Bespoke Studio.

Ten questions for the supplier

Ask for these in writing from the partner workshop or the luminaire supplier, before tender return. Answers can be “not available”; the aim is to know which.

  1. Materials list. Each material and its mass, for the frame, glass, light source, driver, fixings and finish.
  2. Metals. Alloy, recycled content and the evidence for it, and where the metal was sourced.
  3. The carbon figure, if any. Is it a TM65.2 estimate or an EPD? Who calculated it, which version of the tool, what boundary and what service life were assumed?
  4. Made and shipped. Where each major part is made and how it travels.
  5. Replaceable parts. Can the light source and driver be replaced without damaging the fitting, with common tools? Is the product designed for the parts most likely to fail to be reached easily? (CIBSE Journal, 2022.)
  6. Spares and records. What spares are held, for how long, and is there a unique identifier on the product (such as a QR code or tag) that links to drawings and spare sources? (CIBSE Journal, 2022.)
  7. Repair and refinish. Written repair instructions; whether the finish can be renewed rather than the part replaced.
  8. Take-back. Is there a route to return a fitting for refurbishment, reuse or recovery at end of use?
  9. Circularity score. Has the product been assessed with CEAM-Make or CEAM-Specify? By whom, and has anyone independent checked it?
  10. Packaging. What it is, whether it is reusable, and who takes it away.

The questions are also the content of the operation and maintenance file. The O&M information sheet covers what that file contains; the sustainability documents sheet covers the wider paperwork a tender asks for.

Specification wording

Paste into your schedule or specification and replace anything in [square brackets] with your own figures. Wording is a starting point: your specification governs.

Disclosure at tender
Tenderer to provide for each luminaire type [reference]: a materials list by mass; alloy and recycled content of metals with evidence; the embodied carbon figure if available, stating the method (CIBSE TM65.2 estimate or EPD), the person who calculated it, the version of the method, the boundary and the service life assumed; and where each major part is made.
Circularity
Tenderer to state whether the light source and driver are replaceable with commonly available tools without damaging the fitting; what spares are held and for how long; whether repair instructions and a unique product identifier are provided; and the route for return, refurbishment or recovery at end of use. Where the product has been assessed with CEAM-Make or CEAM-Specify, state the rating, who carried it out and whether it has been independently checked.
Claims
Any statement of recycled content, low carbon or circularity to be supported by documents. Where no data exist, the tenderer is to say so; an estimate is not to be described as a verified declaration.

Terms used on this page

Embodied carbon (luminaires)
The carbon emitted making and delivering a product. CIBSE TM65 gives a calculation method for building services, and TM65.2 applies it to lighting.
TM66
CIBSE guidance on assessing how repairable and recoverable a luminaire is, with two tools: CEAM-Make for manufacturers and CEAM-Specify for quick comparison by specifiers.
Environmental Product Declaration (EPD)
A verified document reporting a product's life-cycle environmental impacts in a standard format; two EPDs are only comparable if built on the same product category rules.
CEAM
Circular Economy Assessment Method, the pair of digital tools that go with TM66: CEAM-Make for manufacturers and CEAM-Specify, a quicker triage tool for designers and specifiers.

All lighting terms

Standards and sources

Questions we are asked

What is the difference between TM65.2 and an EPD?

TM65.2 is a CIBSE method that produces a conservative estimate of a luminaire's embodied carbon from its materials and processes. An EPD is a verified declaration of life-cycle impacts to a stated standard. CIBSE says TM65.2 does not aim to replace EPDs. Do not compare the two figures as if they were the same kind of number.

What does TM66 measure?

How circular a luminaire is: whether it can be repaired, upgraded and recovered. It does not calculate carbon. CIBSE published it in October 2021 with two tools, CEAM-Make for manufacturers and CEAM-Specify, a quicker comparison for specifiers.

Does a bespoke chandelier have an EPD?

Probably not. An EPD usually describes a defined product made repeatedly, and a one-off piece made for a project is unlikely to have one of its own. Ask instead for a materials list, a stated method and honest gaps, as the question list suggests.

Can the studio give me a carbon figure for a luminaire?

No. The studio holds no carbon or circularity data for any luminaire. It can ask the partner workshop to provide the information in the question list, and tell you what they say.

Is a low-carbon luminaire also circular?

Not necessarily. The CIBSE Journal's module says low embodied carbon does not guarantee circularity, and a circular product is not automatically low-carbon, though the two are linked.

What should the specification say?

Ask for a materials list, the method and boundary of any carbon figure, recycled content evidence, replaceability of the light source and driver, spares and take-back, and say that an estimate is not to be described as a verified declaration. See the paste-in wording.

Download the factsheet

A two-page A4 PDF with what each document measures, where carbon and circularity sit in a luminaire, the ten supplier questions and paste-in wording.

Factsheet TL-LIG-35 v1.0 (PDF)