The draft regulation is now in circulation to existing consultees prior to a meeting on July 5 in Brussels. I have taken a first look and can tell you that any pretense for a technologically neutral approach has been abandoned. It has been accepted that Tungsten Halogen Low Voltage lamps will have to remain for the foreseeable future however the actual efficiency values are not clearly stated in this draft for consultation, something I find concerning in a consultation paper at this stage of the process.
There are also a few “correction factors” included in the process that makes a distinctly hilly playing field when comparing different technologies and as one would expect TH has the uphill struggle particularly compared with LED and CFL.
I would suggest contacting whoever you know is a consultee on the process and talk to them about this paper sooner rather than later and even email Andras Toth Andras.TOTH@ec.europa.eu The Policy Officer for this issue and ask him for a copy of the draft regulation to comment on by 24 June.
Kevan Shaw June 7, 2011
