Update 20 February 2023
Rob Halliday shares the latest updates on Ecodesign…
Can it really be a year since I last wrote about Ecodesign, the regulations governing the sale of lighting equipment? Well, the date at the top of the last Word file probably doesn’t lie, so yes it is. Government moves at Government’s pace…
Where we were then was that the UK had copied-and-pasted the EU Ecodesign regulation into GB law (which means England, Scotland and Wales but not Northern Ireland), but was starting to talk about writing a new, UK-specific and, in terms of energy efficiency, much more demanding version of the rules as part of the Conservative Government’s drive to just throw out every old EU law at a rapid pace.
But, as I said at the time, we’d also established a good working relationship with the new team looking after all this at the Department of Business, Energy and Industrial Strategy (BEIS), the UK Government department overseeing this. That included a hugely successful open morning/lighting workshop we held for them at the National Theatre last February, which both gave them an interesting day out of the office and opened their eyes to the types and range of equipment we use in entertainment lighting. There were a lot of good discussions held during that day. That the BEIS team were still there talking several hours after they’d said they absolutely had to leave, we took as a good sign… Read the briefing document we prepared for this event here.
It was therefore with a slight sense of shock and alarm that we read their new consultation document on minimum energy standards for lighting products, intended to start from late 2023 – ie. later this year. The document, which appeared in late January, sets out very clearly the continued intent to move to a minimum of 120 lumens per watt (lm/W), then aiming for 140lm/W from September 2027.
The particular requirements of entertainment lighting fixtures, including LED lighting fixtures, make these figures unachievable at present and, perhaps, ever. Current white-source LED moving light fixtures peak at about 70-80lm/W measuring their light sources independently, and about 40-50lm/W measuring light output from the fixture. Multi-colour additive colour mixing fixtures are generally less efficient when creating white light, though usually more efficient when making colour. That sense of fear of being a bit doomed we felt five years ago rapidly returns when reading the first twenty pages…
And then you get to page 21, where you discover the advantages of being pro-active, reaching out, explaining, making your case, and breathing a bit of a sigh of relief. In the section titled ‘Exemptions’, the document says that in certain areas they have judged that exemptions will not require changes, including where “it is not practicable to force a transition to LED lighting at this point in time (eg. emergency lighting and theatre lighting); LED replacements are being phased in but the costs involved in replacing fittings is prohibitive and creates a circular economy risk.”
Then particularly pleasing, the next paragraph which specifically mentions us: “We are pleased to see the development of industry codes of best practice for theatre and film lighting, which is driving a transition towards higher efficiency lighting in that sector, whilst acknowledging that a full-scale transition to LED is a longer-term aim,” I think we are the only sector to be specifically remarked upon in this way in this document.
In talking to the BEIS team since, their stated intention is to leave the exemptions relating to our equipment unchanged. Since those exemptions are quite scattered through the current regulations and don’t always carry an ‘entertainment lighting’ label (because of the routes we had to take to get them accepted by the EU) we are going to work with BEIS to be sure the right bits of text are carried forward. We’re also continuing to encourage them to move to a simpler exemption based around fixtures created specifically for entertainment lighting (using the existing EN60598-2-17 standard) since that would make the regulations much easier to parse and not limit them to current technologies, particularly LED.
However, this is not quite ‘all’s well, carry on’. The consultation does outline the intent to remove the exemption for double-capped T5 fluorescent light sources, since the expectation is that such sources will fall out of production because of changes to the RoHS regulations. This may affect some fluorescent fixtures used in film and television work. BEIS did talk to representatives from the film and television lighting worlds last year, but if this affects you, you should let me know as soon as possible so we can start to make a case for these lamps, if necessary.
In the slightly chaotic way that seems to just be becoming the way things work in the world, a few weeks after this consultation launched, BEIS itself was swept away by the latest Government re-organisation; we’ll now be dealing with the same people, but they’ll be working at somewhere called the Department for Energy Security and Net Zero (DESNZ) – no-one quite seems to have worked out how to say the acronym in conversation yet!
And, of course, Government never ends. Changes to RoHS, particularly the goal of banning the use of mercury, also pose a threat to the arc lamps that we still use in many applications, either because they offer something LED can’t quite yet match, or because we can’t quite afford to replace all those fixtures yet. These are governed by Ecodesign, but also by the separate RoHS regulations. In Europe, PLASA has been working with the group led by Lighting Europe to extend exemptions for our lamps. The UK is not part of Europe any more, and RoHS is the province of a different department to Ecodesign – DEFRA (the Department for Environment, Food & Rural Affairs – which does seem to have survived this last re-organisation untouched!). But for now, they are copying Europe, which means some exemptions have been extended.
For us, it looks like one, covering the kind of lamps used in big followspots and similar fixtures, has been extended – but only until Feb 2025. And another, covering the lamps generally used in moving lights, has been extended for a little longer, until Feb 2027. Neither of those two dates are particularly far away now, and some quick conversations with a few rental companies and manufacturers suggest neither provides enough time to replace the remaining arc equipment, whether because of the costs involved or, in some cases, because suitable LED replacements don’t yet exist. I’d love to hear more opinions about that – and more data to support that case is always useful as we start the process of making DEFRA aware of our concerns.
Find the current Government consultation document on Ecodesign here.
The closing date for responses is 4 April. I will respond on behalf of PLASA and the ALPD towards the end of that period, so if you have any particular issues you feel should be raised perhaps let me know so we can include it in one combined industry response rather than numerous individual ones.
Beyond that, as ever, you can never be sure of a regulation until you see it written down, but we’ll continue to be here offering to help BEIS, DEFRA, DESNZ or any other department that comes along to get it written down as well as they possibly can!
Update: 19 October 2021
Ecodesign rules come into force, including exceptions for entertainment lighting
The revised Ecodesign regulations entered into force at the end of September and are now applicable in all EU member states. The new regulations include hard-fought exemptions for certain stage and studio lights which are: high-output and point-source (discharge) lights; high-power LEDs with high-colour rendering; high-power LEDs with adaptive colour temperature; specific scenic tungsten sources; high-power LEDs with gate (typically used in moving lights with white light source); colour-tuneable light sources (as used in RGB+ LED spotlights), plus an exemption from the standby power requirements for specialist entertainment lighting fixtures.
The revised regulations have been welcomed by the European Entertainment Ecodesign Coalition, the European-wide group of associations representing the entertainment, lighting design, live performance and film/TV sectors, which includes PLASA, Pearle, IALD, VPLT, ALD, DTHG, OETHG, SLF, and STEPP.
The Coalition recognises the notable achievements made by the regulatory committee and the European Commission to find workable solutions for the entertainment technology industry. Most of the concerns regarding stage and studio lighting were addressed, with targeted exemptions allowing the continued use of the vast majority of light sources needed on stage and in film studios. The main reason for the exemptions is the lack of replacement available on the market for technical equipment being used today, namely for certain special purpose lights used on stage.
The Coalition’s aim is to secure sustainable stage and studio lighting for the years to come to guarantee a professional, high-level entertainment lighting and provide the best quality and experiences for lighting design customers, audiences of live events as well as film spectators. Furthermore, the Coalition is committed to further work with the European Commission and the expert group on energy labelling and Ecodesign to provide input on sustainable solutions in stage lighting.
Update: 12 April 2021
UK Ecodesign updated following public consulation
Following a recent public consultation, which PLASA and its members contributed to, the UK Government has decided to implement updated Ecodesign requirements and a re-scaled energy label for lighting products in Great Britain from September 2021.
The new GB Regulations will reflect the updated Ecodesign and energy labelling requirements which will begin to apply in Northern Ireland and the EU from 1 September this year. It will also adopt the amendments made to these requirements by the EU’s omnibus amendment procedure. Secondary legislation to implement these requirements will be laid this summer.
A full Government response setting out the feedback received to the consultation will be published in due course, including a summary of responses to their questions about how to achieve better carbon, energy and resource savings from lighting products beyond 2021.
Update: 03 January 2021
Rob Halliday details the latest Ecodesign developments
The following text originally featured in the 2021 February edition of LSi magazine and was written by Rob Halliday on behalf of PLASA:
During November 2020, the EU agreed to the revisions to the Ecodesign lighting regulation that the entertainment lighting community, including PLASA, had been discussing with them for two years. These changes cleared the way for high-output white LED fixtures able to replace arc lamps used in arena-scale moving lights and followspots, as well as clarifying some other details. Unfortunately, because this regulation does not come into force in Europe until September 2021, they do not automatically become part of post-Brexit UK law.
Because of that, the UK government is proposing to effectively copy the EU regulation as a GB (ie. UK except Northern Ireland) regulation. They had taken the original version of the EU regulation, but entertainment lighting and other industries have robustly presented that it should be the same, revised text so GB and EU regulations remain aligned. Hopefully that is what will now happen.
However, something for you to start thinking about: the entertainment lighting community has also been involved with some UK government-led discussions about their plans for these regulations in the future. These are at the very earliest of stages, but a suggested intent would be to simplify the rules while also tightening them up – perhaps to light source efficiencies of 120lm/W by 2023 and 150lm/W by 2025. PLASA and other members of the entertainment lighting industry will continue to work with the government on this, but be aware – more changes are coming down the road…
Update: 25 November 2020
Contribute to the BEIS open consultation, running until 27 January 2021
We are pleased to share the latest Ecodesign news, authored by lighting designer and LSi columnist Rob Halliday. As you will read, there is a BEIS open consultation running until 27 January which we urge you to contribute to. Find out more about the open consultation.
Just when you think the last detail has been resolved, a new challenge comes along!
In mid-November, the EU voted to accept amendments to the Ecodesign regulation, including the corrections for which the Entertainment Lighting Industry had been pressing hard for over the last two years. These correct some important details for the first version of the Regulation – ensuring, for example, that it was possible for high powered/high light output LED fixtures to meet the requirements of the regulation, encouraging their continued development to replace arc fixtures. Getting these changes made and accepted was a job well done by all who have been collaborating on this process from our side.
Just a few days later came an email from the UK Governments Department of Business, Energy and Industrial Strategy (BEIS), who oversee this regulation in the UK, starting a consultation on the new draft Ecodesign and Energy Labelling Regulations (Lighting Sources) 2021 for the UK…
The issue is that because the EU Ecodesign regulation does not take effect until September 2021, it will not be in effect when Brexit takes place at the end of this year and so will not automatically become British law. The UK Government is therefore preparing its own version of the regulation.
To do this they have effectively taken the European text and created a British version of it. Unfortunately they have done this with the original version of the text, before any of the recently accepted amendments we had worked so hard to achieve…
In talking to BEIS, it is clear that this is an accident of timing rather than some deliberate plot. They have said that their intention is for the UK regulation to at least start of matching the EU version.
However, it would be useful to re-iterate the importance of this through the public consultation that they are running from now until 11.45pm on 27th January 2021.
PLASA and the other UK-based organisations that have been part of this process will be submitting a joint response to this survey to represent all UK based manufacturers and organisations.
However, PLASA feels it would be useful for companies from outside the UK that supply products in to the UK to re-iterate the same point about the importance of a common playing field between the UK and Europe. PLASA is therefore suggesting that such companies from outside the UK submit their own responses to the BEIS survey, emphasising the need for the UK regulation to conform to the ‘Omnibus amendments’ to the EU regulation agreed in November 2020.
The survey and related documents can be found here
03 July 2020: Ecodesign regulations to start September 2021
We are pleased to share with you the latest developments on EcoDesign with this comprehensive summary written by lighting designer and LSi writer Rob Halliday:
It will have been easy to forget in the current world situation – everyone’s had other things on their minds – so this is just a gentle reminder that the EU’s new Ecodesign regulations for lighting will come in to effect next year – September 2021.
As a further reminder: Ecodesign is the regulation that the EU uses to try to encourage manufacturers to develop more energy efficient products by progressively tightening up the efficiency standards products have to meet before they can be sold in the EU. It does not stop end-users from continuing to use any products they have, though of course it may indirectly prevent their continued use. For lighting, the main cause of that would be that tungsten light bulbs no longer meet the efficiency standards (removing this type of source has been one of the EU’s main aims) and so could no longer be offered for sale – so those using lighting fixtures that rely on such light bulbs would no longer be able to use them once they had exhausted their supply of replacement bulbs.
As with all of the EU’s rules, Ecodesign is reviewed on a rolling basis and updated every five years or so. Fortunately in early 2018 the entertainment industry caught that the changes made in the earliest drafts of this new version (in particular, the removal of a blanket exemption for fixtures used for entertainment lighting) would prevent substantial problems to entertainment lighting: the efficiency standards prescribed, really intended for domestic and industrial lighting, made no allowance for the particular demands of entertainment lighting fixtures (squeezing light through a tiny focal plane, for example).
The result if left uncontested would potentially have led to a disastrous scenario whereby all tungsten light bulbs used by entertainment fixtures would be prohibited – but all current LED theatrical lighting fixtures (where the light source is an integral part of the fixture) would also be prohibited through not being efficient enough either when emitting light or when in ‘standby’ waiting to emit light. Ironically arc sources, which are often actually less efficient than LED sources in entertainment applications (particularly when not emitting light – the lamp on with the mechanical dimmer closed) would have been allowed, somewhat contrary to the Ecodesign goals…
A concerted campaign by a number of industry bodies from across the EU, including PLASA, ensured that the EU was made aware of the special requirements of our industry and the scale of the problem that would have been created (directly – no lighting, but also indirectly – the effect on industries from theatre to concerts to film and TV). Our industry was ultimately invited to present its case to the EU, and then to collaborate with the EU to create the exemptions required. This it duly did.
When the final draft of the regulation appeared in early 2019, with a start date pushed back a year from September 2020 to September 2021, it included exemptions that would allow most of our fixtures and light sources to continue to be supplied, detailing in particular a broad range of specialist tungsten light bulbs that were exempt, allowing specialist entertainment lighting fixtures an exemption from the standby power requirements, and revising the definitions of additive colour mixing to allow additive colour mixing entertainment fixtures to be sold. Arc lamps would continue to be exempt based on the tiny size of the arc. The key casualty would be that the tungsten M16 lamps would no longer be available: however with these and a number of older specialist tungsten lamps, users had already reported finding it difficult to purchase those lamps as manufacturer’s stopped producing them, meaning their legality or not was largely irrelevant.
In effect, this industry achieved exemptions for all of the products it uses regularly – and at the same time made the EU very aware of its presence. At an Ecodesign cocktail party which took place after the final meeting to agree the new regulation, entertainment lighting was specifically mentioned and welcomed to the Ecodesign community.
However, the final text contained one revision from our proposed text, a seemingly innocuous change in a section (annex III point 3(w)) dealing with special cases such as high CRI LED sources, high light output LED sources (which are currently impossible to make meet the required efficiency standard), and the fluorescent fixtures still used in the film world: a requirement to meet ‘one or more’ of a series of conditions was changed to say ‘two or more’. Unfortunately this meant this section of text became largely redundant, offering no exemptions for the products it was supposed to protect. It would mean that, in particular, developing very high output white LED fixtures – big moving lights or followspots -might not be possible. Ironically, because arc sources were still exempt it would actually encourage the continued use of these sources even though they were likely to be less efficient than the ‘not efficient enough’ LED sources.
Unfortunately, at around the same time the EU was beginning its review of its separate but inter-related ROHS regulations, aiming in particularly to completely stop the use of mercury. The difficulty here is that arc lamps contain mercury, so if on the one hand ROHS outlawed arc lamps and on the other Ecodesign outlawed the kind of high-output white LED fixtures that could replace arc lamp-based fixtures, we would be left once again with no suitable tools for these types of fixtures. Or we would have to campaign for continuing exemptions to the ROHS regulations for arc lamps.
The industry noticed this issue and raised it with the EU immediately. The discussions about the best way of resolving it have continued for the almost 18 months since. A Zoom meeting to discuss this and other changes, corrections and clarifications proposed by other industries (beyond lighting) took place in the first week of June; Adam Bennette attended that meeting on behalf of PLASA. Prior to that meeting, the EU had shared a revised wording for the problematic section which largely resolved the issue, but we felt some improvements could be made to it and have suggested those. Unfortunately the meeting ran out of time, and no final decision will now be made until September 2020.
However, we are reasonably confident that the issue will be addressed. Taken together that should mean that, while fixtures produced for sale in the EU will still have to conform to the Ecodesign regulations, all reasonable fixtures should be able to do so by either meeting the requirements or being permitted by one of the exemptions, particularly those for light sources designed and marketed for use in entertainment lighting. The revised text should also both permit and encourage once again the development of high-output white LED fixtures to replace long-throw arc moving lights and followspots.
The text of the regulation as it stands now is available here. The revised text will be available once it is agreed upon.
There is still, of course, uncertainty as to how this new regulation will now play out in the UK because of the ongoing uncertainty surrounding Brexit. However it seems unlikely there will be a more stringent UK-version of the regulation, so by meeting the Ecodesign requirements manufacturers will still have access to the European market and the UK market.
For end users, there is still some uncertainty about how this period will play out. Many large organisations (venues and rental companies) had been moving rapidly to LED sources, but this progress is likely to be affected by financial uncertainty post-Covid. Smaller venues have had concerns about the costs and other implications of having to upgrade to LED-based rigs – both the fixtures and the supporting infrastructure. In some cases there may be no pressing need to do so: Ushio have committed themselves to the HPL lamp used by the ETC Source Four range, for example. But users of other fixtures are already finding difficulty sourcing the lamps they require beyond any stocks the already hold, which is likely to force them into upgrading their equipment if funds are available. This of course presents new opportunities for PLASA members.
PLASA is also continuing to be part of the discussions of the ROHS review to ensure that the voice of the entertainment lighting industry is also heard there.
10 December 2019: The Ecodesign regulation, which was adopted on 1 October, is now published in the Official Journal of the Union.
This follows a lengthy industry campaign to safeguard the use of stage and studio lighting by passing several key exemptions. You can view the full document on the EUR-Lex website as well as download it in all official European languages.
14 January 2019: Further exemptions for the live performance, lighting design and film sector guarantee that vast majority of stage and studio lighting can continue to be used.
On 17 December 2018, Member States voted on the Commission proposal to revise Ecodesign regulations for lighting products also called “Single Lighting Regulation”.
The European Entertainment Ecodesign Coalition (a European-wide group of associations working in the entertainment, lighting design, live performance and film/TV sectors) welcomes the outcome of the Member State vote as our remaining concerns regarding stage and studio lighting were addressed by the expert group.
Because our sectors aim at providing the best quality and experiences for lighting design customers, audiences of live events and film spectators, the Coalition had introduced a number of amendments covering essential requirements for our businesses.
The European Commission had introduced a first technical exemption for the sector in July 2018, allowing around 80% of specific lamp types used in the live performance and film sector to be exempted from Ecodesign requirements:
After exchanging views and sharing some technical information with EU Member State experts, the text was revised a second time to include the following points:
- Stand-by power: Clarification to exempt networks used on stage from requirements on stand-by power
- White Light Sources for specific needs
- Colour tuneable light sources: Extension of the wave-length of Green
- The list of lamp bases: Additional sockets will benefit from an exemption
The mean reason for the above mentioned demands is the lack of replacement available on the market for technical equipment being used today, namely for certain special purpose lights used on stage.
With the additional exemptions voted in December 2018, the vast majority of light sources needed on stage, in specialized lighting design as well as in film studios can continue to be used.
The European Commission will publish a consolidated version of the text at the end of January 2019. The vote in European Parliament (scrutiny procedure) is scheduled for March 2019.
The Revised Ecodesign rules will be applicable to Member States as of September 2021.
NB: PLASA will be releasing guidance documents in due course.
27 November 2018
PLASA and the European Entertainment Ecodesign Coalition have produced two comprehensive documents outlining the current position including details of the four key issues that remain.
17 October 2018: The EU Commission has released a revised version of their proposed Ecodesign regulation…
They intend for these to be the final versions of these regulations and are available to read here:
- https://members.wto.org/crnattachments/2018/TBT/EEC/18_5215_00_e.pdf
- https://members.wto.org/crnattachments/2018/TBT/EEC/18_5215_01_e.pdf
- https://members.wto.org/crnattachments/2018/TBT/EEC/18_5216_00_e.pdf
- https://members.wto.org/crnattachments/2018/TBT/EEC/18_5216_01_e.pdf
This version is largely unchanged from the previous version (July 2018 – see summary below), with the exemptions covering many areas of entertainment lighting remaining in place. It now includes a new exemption for some fluorescent lamps used in the film industry.
Outstanding requests…
There are still four areas we are trying to address, these are:
- Requirement for lighting fixtures to use less than 0.5W of power in standby mode (when not emitting light), which is not achievable for DMX-controlled lighting fixtures that have to respond immediately to cues.
- Inability of high-powered white LED sources to meet the efficiency requirements because of the combined impacts of the Auger effect, thermal effects and in-built optics. Many such sources are far from achieving the regulation limits.
- The definition of green used in colour-tuneable (additive colour mixing) fixtures, which is not set at the right point for the most efficient design of colour mixing systems.
- A number of specific lamp bases and white light sources for which exemptions were requested but not given. Particularly confusingly, some R7 lamps are exempted while others are not.
What happens next…
The regulations now enter a consultation period during which member states can comment on the regulations through their appropriate government body. In the UK this is the Department of Business Energy and Industrial Strategy (BEIS), who have been well briefed by our industry and are well aware of the issues.
Every EU country is being encouraged to connect with the ministry in their country responsible for this regulation, and made aware of the issues the regulations still present to entertainment lighting. The European Ecodesign Coalition, of which PLASA is a member, is also working to ensure our outstanding requests are addressed.
The Coalition have presented a joint statement to the EU Commission outlining its position, available here.
PLASA has also submitted its own statement, available here.
What you can do…
If you are a PLASA member outside of the UK, please identify the relevant contact in the ministry in your country concerned with this regulation and contact us. (technical@plasa.org)
Whilst there are no guarantees that there will be success we do believe your support and contribution will be helpful.
Key dates…
- The Public Consultation closes 9 November 2018
- The Final Draft is agreed 17- 20 December 2018
- The Regulation is voted on by Member states Spring 2019 (where it will most likely pass)
- The Regulation comes into force 2021
For more information, or if you have any questions, please contact technical@plasa.org
10 September 2018: The EU Commission has released a second draft of their proposed Ecodesign regulation
Adam Bennette has provided a summary of what it could all mean which can be viewed via the link below. Please note – the purpose of this is to aid understanding and some of the lamps are still being debated.
What’s next?
The third draft will be published in the next few weeks with the law being published on December 4. During this time MEPs and government representatives can raise objections and ask questions.
The Ecodesign working group intend to publish guidelines to support MEPs who are not technically minded.
25 June 2018: Ecodesign industry task force ‘positive’ as EU submits revised draft
As the professional entertainment lighting industry continues to seek an exemption for specialist lighting from the European Union’s Ecodesign regulation, an industry task force has said the situation is “far more positive” and “greatly improved” following the latest round of talks with the EU. The EU Directorate-General for Energy has now passed a revised draft of the regulation, with its content expected to be revealed in a few weeks as it progresses through the committee stages of the process.
The Professional Entertainment Lighting Products Ecodesign task group – the body representing the industry during the public consultation – has confirmed there will be a ‘comprehensive’ list of exempted lamp base types, but some specialist lamps used for non-entertainment purposes may not be included. The industry task group comprises Adam Bennette (PLASA), Christian Allabauer (OETHG), Randell Greenlee (VPLT) & Silke Lalvani (PEARLE). It released the following statement:
“On 20 June 2018, the period of public consultation for the proposed Ecodesign regulation – that will affect lighting products of all types – expired. The EU DG Energy department has passed on a revised draft to the next stage of the legislative process. We expect to know its content within a few weeks as it progresses through the committee stages of the process of turning it into a law. Although much still remains to be known, the situation now is far more positive than many had feared and greatly improved since our public meetings earlier this year.
“Our petitioning team made a clear case for exemptions for our industry – including for stage, studio, film and live event purposes – and we have received strong indications that the main arguments of the case have been accepted. There will be a list of exempted lamp base types that will include many of the specialised tungsten and discharge lamps we use. We can expect the list to be comprehensive, but we should also expect that a few types we have been using will not be exempted if they are in use for other common non-entertainment purposes. There will be an exemption for colour tunable light sources, but the details have not yet been provided.
“The text of the regulation will be published publicly in November this year and is to be enacted in law in September 2020. More specific details will be available shortly, and these will be disseminated as soon as they are confirmed. There may be more work to do and more details to clarify but, until we see the revised draft, it would be prudent to remain calm and patient.”
