As many of you are aware, having succeeded in banning the incandescent lamp as of September this year, the process to review Energy Using Products ( EuP) has proceeded to tackle reflector lamps and domestic light fittings. Earlier in the year, between February and May the draft chapters of the report were posted on the website http://www.eup4light.net/. As the PLDA “stakeholder” I went through the chapters critically and produced comment documents for each chapter, these are also on the EUP4Light website.
The Stakeholder’s meeting was held in Brussels on the 26th May and was supposed to answer the comments that had been made. It was pretty clear that VITO, the company being paid to do the research and report writing, could not produce a coherent case for the banning of most Tungsten Halogen reflector lamps as there are no acceptable replacement technologies. They did, however invent a new metric, Lumens per Euro that combines initial cost, and estimate of the cost of energy used throughout the lamp’s life. Of course this metric works entirely in the favour of LEDs.
The final chapter and recommendations for the legislation were not provided, these will be provided in August with about three weeks to comment and the final report will be published on September 30th. At this point , unlike the first stage there will be no further comment nor any further meetings to address the stakeholder’s concerns. This will be a done deal. Given the risk of further extremely inappropriate legislation I find this somewhat unacceptable.
I urge you to log on to the eup4light website, register and have a look at the working papers and comments section. Please let me know if you have any difficulties registering and accessing this information and I will try and help. Meanwhile watch this space and I will report back once the final chapter is open for comments.
Kevan Shaw
Don’t you think that most of the bulb ban “legis”lation is illegal even within “EU logic” simply because the bans often violate one or more of the criteria specified in Article 15, No. 5 of “DIRECTIVE 2005/32/EC”?