RoHS Update May 2023
Rob Halliday shares the latest updates on RoHS…
With Ecodesign for entertainment lighting under control, we need to turn our attention rather urgently to the potential impact upcoming changes to the RoHS regulations in Europe and the UK might have on entertainment lighting.
A big goal in the next round of changes to these regulations is the removal of mercury from products. Unfortunately mercury is a key element in the arc lamps we use, helping to create a decent colour output. There is no alternative element which can achieve this.
Currently these lamps can continue to be sold because of two exemptions. In the European regulations these are mercury exemption 4(e) metal halide lamps, and mercury exemption 4(f)-I other discharge lamps for special purposes. In the UK the same exemptions are identified as 8 and 9.1.
In both the EU and the UK, the metal halide exemption runs until February 2027, but the other discharge lamps exemption expires in Feb 2025 – which is quite soon now.
We had thought that effectively all arc/discharge lamps we now use in moving lights and followspots were metal halide (certain followspots use xenon arc lamps, but these do not contain mercury and so are not covered by these rules).
However, it has now transpired that some lamps – particularly the high pressure discharge lamps which Osram sell as their Sirius HRI line and Philips/Signify as their Platinum MSD line, are not. These are the lamps typically used in ‘beam’-type fixtures such as Clay Paky’s Sharpy, Robe’s Pointe and similar, including a number of new models just launched at Frankfurt – fixtures which require a tiny source size. The confusion has come because many distributors and dealers identify these as metal halide lamps, but their manufacturers actually classify them as 4(f) lamps since they contain only trace amounts of halide elements.
This means that as things stand right now the exemption covering these lamps will expire in Feb 2025.
What happens then becomes a bit of a muddle. New fixtures using these lamps will not be allowed to be sold, but the lamps will continue to be allowed to be sold to support fixtures that are already in use – unlike Ecodesign, RoHS allows the continued sale of spare parts so that existing products are not suddenly rendered useless, and lamps count as spare parts in this case. Though the question then inevitably becomes how long lamp manufacturers will continue to produce those lamps given that demand for them would potentially have peaked.
The problem is that there are no real alternatives to these lamps for these kinds of fixtures. They rely on a bright but very compact ‘point’ of light around which to build a narrow-angle optical system, which LEDs have a hard time matching. Some fixtures of this type using laser sources are available, but may not match the colour rendering of the arc fixtures and have potential issues relating to their light source (with certain countries not allowing these products to be sold because of the word ‘laser’ attached to them).
This means that in order to allow new fixtures of this type to be made and sold, we need to present a case for the 4(f) exemption to continue. For that we urgently need evidence as to the number of new fixtures in the works that would use these lamps, and then evidence as to why they could not be made using alternative light sources (such as LED or laser). We have some of this information, of course, but more data from more manufacturers is always helpful. If you’re able to share such information please do get in touch – firstname.lastname@example.org
In the UK a complication is that the relevant UK Government agency, DEFRA, this year introduced an application fee of £39.721 for anyone wishing to apply for a new exemption or renew an existing one, despite protests from us and others. Who pays that will need to be worked out…
Beyond that, this is a sign that we need to start planning for the demise of other arc lamp fixtures beyond Feb 2027. This increasingly feels like less and less of a problem since LED equivalents are being rapidly adopted in most classes of moving lights and followspots and the RoHS ‘spare parts’ rule should allow a longer period to replace existing arc fixtures. But if you are a manufacturer, distributor or user who can see reasons for needing to extend the 4(e) exemption (perhaps in relation to very large, high-output fixtures and the timeline for creating LED replacements for those), it would be good to hear those as well – email@example.com