Ecodesign Regulation Failure?

Posted July 4, 2012 // Tagged as Blog // 8 Comments ↓

We are now 3 years into the European ban on incandescent lamps. Has it achieved the promised goals of energy savings? By this time we would have expected there to be some evidence that energy savings would be apparent. Working with Catherine Hessett, Coordinator of the Spectrum Alliance and a professional statistician we took a look at the published electricity supply figures for the UK between 2009 , before the ban and December 2011 looking for some significant and identifiable energy savings. Well there was a reduction in energy use however this was more commensurate with the reduction in economic activity brought about by the economic recession so we concluded, if there was a reduction in domestic energy use then it was so slight as to have been negligible and certainly not as significant as the legislation promised.

Thanks to the assistance of David Martin, MEP we placed a written question to the European Parliament on this issue:

Subject: Proven effectiveness of Commission Regulation (EC) No 245/2009 implementing ecodesign requirements for non-directional household lamps
The following statement was made on 8 December 2008 (IP/08/1909) on behalf of the Commissioner for Energy, Andreas Piebalgs
‘At today’s meeting of the Ecodesign Regulatory Committee, EU Member States experts endorsed the European Commission’s proposals for a regulation progressively phasing out incandescent bulbs starting in 2009 and finishing at the end of 2012. By enforcing the regulation of switching to energy saving bulbs, EU citizens will save close to 40 TWh (roughly the electricity consumption of Romania, or of 11 million European households, or the equivalent of the yearly output of 10 power stations of 500 megawatts) and will lead to a reduction of about 15 million tons of CO2 emission per year.’
This regulation has raised criticism from EU citizens and organisations regarding the hazards of mercury waste, adverse medical impacts on a significant minority of the population and much higher costs to households in replacing lamps. These criticisms need to be addressed by providing positive proof that the goals in energy saving and reduction of CO2 emissions have been achieved by this regulation.
The speed of implementation of this regulation was declared to be a key factor in achieving the claimed benefits. The first two stages of this legislation have been in force for over a year. Proof of the effectiveness of the regulation is essential ahead of the review required in 2013 with a view to amending the regulation in 2014.
1. What monitoring has taken place to measure the effectiveness of this regulation in achieving its objectives?
2. What proof is there that the expected reduction in energy use attributable to this regulation is now being achieved?

We have now received the answer:

Answer given by M. Oettinger
on behalf of the Commission

It is still premature to draw conclusions as regards the effectiveness of the Regulation on household lamps 244/20091 as major categories of incandescent bulbs are only phased out in September 2011 (60W) and in September 2012 (40W and below), with retailers allowed to sell their remaining stocks even beyond those dates. The Regulation will – like other regulations in the frame of the ecodesign process – be subject to a review in the light of technical progress, at the latest five years after its entry into force (2014). During this review, the Commission will collect data in a systematic way that will allow to judge the effectiveness of the regulation.

Apart from the fact this does not answer either of our direct questions this seems to show that there has either been no work so far on this topic or the results are similar to those that we found in the UK , i.e. there is no discernible energy saving being generated by the ban. As the legislation has to be reviewed next year if the work is not being done now the results will not be available next year to consider in the required review.

One interesting and useful piece of research that has recently been published is the Household Energy Use Study commissioned by DEFRA.This studied energy use in 251 owner occupier households between April 2010 and April 2011. It makes fascinating reading and when the full data is made available as is promised will allow some further interesting analysis. Meantime there are some interesting points that can be gleaned from the report.

As has been shown in previous studies the amount of lighting energy used in households is far more dependent on behavior than the type of lighting equipment used. Ultimately the length of time a light is left switched on has significantly more influence on total energy used than the wattage of the lamp. Another interesting point is that the proportion of electricity used in households for lighting is now being overtaken by that used for Audio Visual and Computers in the home. Despite this no one so far is proposing that plasma large screen tellys are banned in favour of LED types that use a fraction of the electricity!

Much has been said about the quality, or lack thereof, of Compact Fluorescent Energy Saving lamps. The EcoDesign regulations made some effort to include quality criteria to answer criticisms by user groups. Each European country is supposed to undertake necessary market surveillance to ensure that the products placed on the market meet these quality criteria. In the UK a new QUANGO , the National Measurement Office, (NMO)was set up to deal with this across all of the EcoDesign regulations. There was some discussion before it was set up as to what it would be doing in respect of the lighting regulations. So far it has undertaken one study on domestic lighting and the results were published here. It was always acknowledged that there would not be sufficient funding to realistically tackle the vast number of lamps imported and sold each year, however this report really does show that quality standards are not being met and that NMO are taking a softly softly approach with suppliers rather than a strict an punitive approach. During the MTP consultation we were told that these studies on lamps would be annual however I had a conversation with a spokesman for NMO who absolutely refused to say if or when another study on domestic lamps would be taking place.

As things stand and from the meager evidence available I would say that, certainly as far as domestic lighting is concerned EcoDesign regulations are neither delivering the promised energy savings nor the guarantee of reasonable quality of lamps to the domestic market in the EU.

Kevan Shaw July 4, 2012

8 Responses

  1. peter

    July 5th, 2012 at 15:16

    Good point about following things up:
    Politicans, their hangaround cronies and their expensive hired-in consultants rarely if ever follow up on what their grand promises might achieve. If challenged, they mumble about checking it in future, ie when they are out of office, so someone else can carry the can for their idiocy.

    Not only is banning what Johnny wants to use in his bedroom irrelevant in the larger scheme of electricity generation and grid distribution
    the token nature of the light bulb ban itself in terms of energy savings has also long been evident eg…..

    Scientific Alliance and the Cambridge Network, September 3, 2009
    Alec Broers (1992 Head of Cambridge University Engineering Department, 1998 Knighted for services to education, 2001 President of The Royal Academy of Engineering, 2004 Becomes Chairman of the House of Lords Science and Technology Committee,2008 Becomes Chairman of Diamond Light Source Ltd., United Kingdom’s largest new scientific facility for 30 years.)

    ” A study by VITO consultants showed the following breakdown of lamp use in European homes in 2007:
    • 54% incandescent (down from 85% in 1995 and still decreasing)
    • 18% low-voltage halogen (and increasing)
    • 5% mains-voltage halogen (and growing)
    • 8% linear fluorescent
    • 15% CFL
    So, if we assume that all remaining filament bulbs are replaced by CFL at some point in the future,
    that these bulbs are used to the same extent as those they replace and that the energy reduction per bulb is 80%, the total reduction in EU energy use would be
    0.54 x 0.8 x 0.76% = 0.33%.
    This figure is almost certainly an overestimate, particularly as the inefficiency of conventional bulbs generates heat which supplements other forms of heating in winter. Which begs the question: is it really worth it? ”

    >> LEDs might be substitutred for CFLs in some respects
    interpreting it today, but the principle still holds.

    The interesting point is of course also the opposite:
    So decreased use of incandescents = lowered savings
    while maintained use of incandescents = what people want to use.

    They impose what seems efficient,
    and forget what is effective….

  2. peter

    July 5th, 2012 at 15:29

    Also good point about Quality Control.

    The EU Stalinist Approach,
    is to remove free market competition by banning popular bulb types,
    set up an Orwellian sounding “EcoDesign” commitee that decides what people can or can’t buy,
    and in lieu of market mechanisms that rewards quality by increased voluntary purchases,
    relies on underfunded inspectors who happily accept the dubious lab based specs (eg brightness ratings) that manufacturers claim for their products, products which (of course) never have lifespan warranties either, that are commensurate with the lifespans claimed.

  3. Peter

    July 9th, 2012 at 21:39

    Re the Cambridge Network research as per above

    About their Scientific Alliance mission,
    that played a part in the above quoted study….

    “Scientific advances have provided, and will continue to provide, solutions to many environmental problems.
    While differences of opinion are welcome and, indeed, play a vital role in the development of both science and society, the Scientific Alliance is concerned about the many ways in which science is misinterpreted and at times misrepresented.

    If optimal use is to be made of currently available resources, policies must be based upon sound and reliable information. The Scientific Alliance provides a forum for addressing environmental problems based on sound science.”

    Unfortunately, as recently highlighted by the BBC relating to the Higgs boson discovery,
    few scientists get politically involved, hence the unscientific
    bandying about of big bulb ban savings figures without regard for overall facts.

  4. peter

    July 11th, 2012 at 16:51

    Extensive further comment on the DEFRA study here:

    As seen, households with CFLs actually use more electricity…

  5. Rich Mintzer

    July 11th, 2012 at 18:47

    Great inforamtion but a “contact us” page would be a wonderful way of generating support. I’m in the US and I wrote an article for about the problems with banning the incandescent bulb back in January – I received over 1,200 comments, which was wonderful – they have been taken down by now on AOL. I’m writing another story for a US magazine and would love to interview Kevan Shaw. How can I reach him or if he sees this, can he please reply. I’m at Thank you,


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