Review of Ecodesign regulation 244/2009 stage 6
The Consultation meeting that took place in Brussels on 25 November revealed clearly that the EcoDesign process, particularly for lighting products is now only a political action. The proposal in the original legislation was that a review should take place of stage 6 as it was based on the availability in the market of higher efficiency mains voltage tungsten halogen lamps (MVTH) by 2016. This has not transpired due to a lack of investment by lamp companies in the relevant technologies due to the uncertainty of the future market for these lamps specifically because of European regulation. The challenge in creating a sufficient increase in performance to meet the target set in 2008 is significant so time and effort would have needed to be diverted from the starchild technology of solid state lighting (SSL)and the somewhat unrealistic expectations that OLEDs will provide yet another revolutionary technology.
In the meeting the majority of the national representatives spoke against delay or removal of the ban, not for substantial reasons of energy savings but because it might be seen as a precedent for delays or revisions for other products in the EcoDesign system. There was also considerable support not to look at this issue in isolation but conflate it with the omnibus review of the regulation next year to save these civil servants from having to attend any more meetings where they are clearly completely out of their depth on fundamentals of the technologies being discussed.
The gloves are also off the conceit that these regulations are “Technology Neutral” Clear statements were made that funding would be provided for SSL but not other research. The UK representative claimed that the statements in lighting industry press clearly showed that SSL was the only future for lighting .This obvious gullibility to marketing messages is truly scary in the context of pan European regulations that will, in effect kill off the only remaining bulk lamp manufacturing in Europe, which is tungsten halogen.
There is also seemingly no need to prove that the existing regulation has been effective in its core purpose of saving energy. The argument here is that energy use may have gone up despite the regulations but if the regulations had not been in place the increase would have been far worse! There will be no evidence offered that the regulation has been effective in any way and more unbelievable claims are being and will be made to extend the effects of regulation. It was pointed out that the regulation has been very effective in bringing to the public’s attention that something was being done about energy use in Europe.
As for any negative impact on consumers, these are brushed under the carpet of savings on energy bills. The unrealistic life in service expectations of extortionately priced SSL lamps, again largely statistical rather than actual, feed this argument. Health concerns? Not the concern of this process SCENHIR deals with that. Product safety? Again not a concern of this process. In the last year there have been 6 recalls of LED replacement lamps that I am aware of. These have ben for life safety issues, touchable parts of the lamps becoming live to mains electricity. Throughout my long career in lighting I can only remember one recall of an incandescent lamp and that was because some shattered when they failed at end of a full service life.
There was some indication of the expectations of the omnibus review. Spearheaded by Sweden and vociferously supported by CLASP the umbrella research organisation funded by the green pressure groups including WWF, Greenpeace etc. the proposal is that only A class lamps should be available in the market by 2020 if not sooner! This is only achievable if SSL actually delivers the more extreme claims for advances currently made by the marketeers. Neither Low Voltage Tungsten Halogen nor Compact Fluorescent lamps can get close to this. Even SSL will not be able to deliver the warm colour appearance good colour rendering light that we are used to at the levels of “efficiency” demanded. The near future looks like becoming cold and dead looking place.
In the rest of the world the lamp efficiency regulations have not proceeded with either the pace or completeness of those in Europe. The USA regulations have come into force, eventually, however they do not make impossible demands and while some of the lowest efficiency lamps are slowly disappearing from the market incandescent and MVTH lamps remain legal and available. In Australia, the first major country to set efficiency targets that prevented the sale of traditional incandescent lamps MVTH have come into the market along side CFL. The recently elected government is now actively considering rescinding the original legislation as it has not been shown effective and is deeply unpopular. New Zealand stepped back at the eleventh hour and abandoned legislation. Canada has yet again postponed the legislation and China, despite announcing legislation has not, as yet, provided details or dates for implementation.
Europeans are being ill served by the Brussels Eurocrats not only on lamps but on an increasing number of issues. Sadly European jobs and industries are being slowly sacrificed on the alter of process and paperwork. Within the individual Civil Services of the member states there is a general push compliance and a quiet life rather than the questioning of the rules and the rule making process in the interests of the individual states.
Kevan Shaw 28 November 2013