2026 mercury lamp ban: what it means for your quotes

The European Union is banning the production, import and export of specific mercury-containing lamps under strict deadlines: halophosphate phosphor lamps from 31 December 2025, and tri-band phosphor lamps from 31 December 2026 [1]. For installers and lighting studios, this means these light sources are permanently disappearing from the market [1]. Existing stock may still be sold off, according to industry body licht.de [2], but the shift to LED is now unavoidable. This has direct consequences for quotes in progress and the material costs of your projects.

The hard deadlines for tri-band and halophosphate lamps

The European Union is further tightening the rules around mercury-containing products. Regulation (EU) 2024/1849, published on 10 July 2024, amends the earlier Regulation (EU) 2017/852 on mercury [1]. This new regulation bans, from 31 December 2026, the production, import and export of tri-band phosphor lamps for general lighting purposes that were not already covered by earlier bans [1]. This ban specifically applies to tri-band phosphor lamps containing less than 5 milligrams of mercury per lamp [1]. In addition, the same ban already applies from 31 December 2025 to halophosphate phosphor lamps for general lighting purposes containing less than 10 milligrams of mercury per lamp [1].

According to German industry body licht.de, linear and non-linear tri-band phosphor lamps for general lighting will no longer be placed on the market after 31 December 2026 [2]. The same organisation reports that linear and non-linear halophosphate phosphor lamps, compact fluorescent lamps for general lighting, and certain high-pressure sodium lamps exceeding specific mercury thresholds will no longer be placed on the market after 31 December 2025 [2]. Since this is a claim from a secondary industry source, it's worth noting that the official EU regulation itself is primarily aimed at production, import and export from the stated dates of 31 December 2025 and 31 December 2026 [1]. According to licht.de, lamps already purchased that fall under this phase-out may continue to be used as normal, and existing stock may be sold off [2]. There is therefore no direct obligation to remove working lamps immediately, but replacement is unavoidable in the longer term.

The earlier steps under the RoHS directive

The upcoming restrictions on mercury-containing lamps follow on from earlier market restrictions. Under the RoHS directive (Restriction of Hazardous Substances), major steps were already taken. Linear fluorescent lamps of types T5 and T8, for instance, have not been allowed on the market since 25 August 2023 [2]. For circular T5 fluorescent lamps and compact fluorescent lamps without an integrated ballast, this ban already took effect on 25 February 2023 [2].

Manufacturers such as LEDVANCE provide information on these changes and the alternatives available under RoHS directive 2011/65/EU [5]. The market's focus is now fully on the shift to LED technology.

The financial reality of waste management and recycling

When drawing up a quote for a renovation project, you need to account for shifting waste-management costs. Stichting LightRec Nederland has set the waste-management fee rates for 2025 and 2026 [3]. This fee is paid by producers and importers when placing new products on the market, which has a direct effect on the purchase price of your materials [3]. It is therefore not an amount you as an installer separately charge afterwards for taking in old lamps; handing in discarded lighting at a collection point remains free of charge.

The rates show a clear difference between old technology and LED. For legacy fluorescent tubes and compact fluorescent/gas-discharge lamps, the waste-management fee stays stable at €0.14 per unit in both 2025 and 2026 [3]. The fee for LED lamps, by contrast, rises from €0.05 in 2025 to €0.07 in 2026 [3]. Rates are also changing for luminaires. For luminaires weighing more than 750 grams, the fee rises from €0.19 in 2025 to €0.21 in 2026 [3]. Lighter luminaires of 750 grams or less see a rise from €0.05 in 2025 to €0.07 in 2026 [3]. These increases in recycling fees for LED products are passed on in the purchase prices of new luminaires and light sources in 2026.

From old tube to LED luminaire in the quote

When you draw up a quote to replace old fluorescent systems, you face a choice: retrofit or full replacement. Manufacturers such as Philips offer solutions like the InstantFit HF tubes, which fit directly into existing luminaires and work with electronic ballasts [4]. Philips also provides checklists for rewiring and emergency-lighting applications to support installers with risk assessment before, during and after installation [4].

Still, a complete luminaire replacement is often the technically better and safer choice for the long term. Old luminaires often have plastic that has become brittle from UV exposure and heat, and the internal wiring and lamp holders are frequently worn. Rather than risk retrofit tubes in aging housings, it's usually better to specify complete LED luminaires in your lighting plan.

For office environments and schools, LED panels are the standard solution for an even, glare-free light distribution. In industrial halls or warehouses with high ceilings, high bays / floodlights provide the light output and durability needed. For retail projects and showrooms, 3-circuit track rail systems combined with flexible track spots give you the freedom to adapt the lighting to changing layouts. For larger renovations in distribution centres or supermarkets, modular light line systems are the fastest way to cover distance during installation. Don't forget to include emergency lighting directly in the design, as these luminaires are often wired to the same circuits and must meet strict legal requirements.

Presenting tax benefits smartly to the customer

A full switch to LED lighting requires a bigger investment from the end customer than simply replacing individual lamps. You can make the business case in your quote more attractive by pointing to tax schemes such as the Dutch Energy Investment Allowance (EIA). Do note the conditions, though: these schemes require the client to be liable for corporate income tax. This tax benefit therefore does not apply to schools, municipalities, or many healthcare foundations. In addition, the specific asset must meet the requirements on the official Energy List of the Netherlands Enterprise Agency (RVO).

By contrasting the technical risks of retrofit with the energy savings and longer lifespan of complete LED luminaires, you give the customer a clear set of options. Factor the rising 2026 recycling fees into your calculations, and make sure your quotes are finalised before year-end to avoid surprises in material costs.

Sources

• [1] eur-lex.europa.eu
• [2] licht.de
• [3] lightrec.nl
• [4] lighting.philips.com
• [5] ledvance.com

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Summary

The next phases of the EU mercury ban take effect on 31 December 2025 and 31 December 2026. Read what this phase-out and the rising 2026 recycling fees mean for the material costs in your current quotes.