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.

~ Rob Halliday