2023 Ecodesign update
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.
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!