European Commission : Position from Ban The Bulb

Summary

Ban The Bulb welcomes the efforts of the European Commission to improve the energy efficiency of the domestic lighting sector and believes that the implementation of ambitious energy efficiency standards will allow the EU to lead the world in efforts to tackle climate change.

Ban The Bulb wishes to propose the following measures, which have been designed to encourage the rapid refinement and uptake of the most energy efficient light bulb designs currently available:

Compact Fluorescent Lamps (CFLs) already offer energy savings of 65% - 80% and the best designs of CFL should form the basis for any minimum energy performance standard within the next 3-5 years for the majority of domestic light bulbs sold in the EU27.

LEDs already offer energy savings of 90%, instant bright light of a good quality and dimmability. The minimum energy performance standard for all domestic light bulbs should match and/or exceed LEDs within 5 years.

Exemptions to these minimum energy performance standards should only be made when an overwhelmingly strong technical, medical, practical or financial case has been made in an open, transparent and evidence-based fashion.

An ambitious energy performance standards for domestic lighting could save 86TWh of electricity per annum by 2020 whilst the least ambitious standards, supported by the lighting industry, equates to only 22TWh of electricity being saved by 2020.

If all of the excess electricity needed to power less efficient light bulbs were produced using coal-fired powered stations this would mean the annual release of an additional 53 million tonnes in CO2 emissions (830,000 tonnes CO2 per TWh x 64TWh).

Based on the present price of carbon dioxide per tonne (€20) on the EUETS this would equate to an annual opportunity cost of approximately €1 billion.

1. Incandescent light bulbs

Domestic incandescent light bulbs have a number of significant disadvantages.

These include:

(i) Very short lifetimes (1000 hours)
(ii) High replacement rates (6 – 15 units over the lifetime of a single CFL)
(iii) High embedded energy and resource costs over the lifetime of a single CFL
(iv) Domestic running costs 60% higher than CFLs (approx €15 each per annum)
(v) Higher carbon emissions via power stations
(vi) Mercury emissions, into the atmosphere, via coal power stations (3x higher)
(vii) An added burden to the electricity system during periods of peak demand
(viii) Requirement for greater installed capacity across the EU
(ix) Hot incandescent light bulbs can cause homes to catch fire

The lighting manufacturers have a vested interest in protecting their existing technologies, factories, market shares and profits at the expense of the energy bills of EU voters, EU-wide energy security and global impacts on the environment.

2. Energy performance criteria

Ban The Bulb would like to see energy performance standards determined in an open and transparent fashion. In particular, clarity is required in the following areas:

(i) The levels of energy performance that are to be achieved over x, y and z years
(ii) The domestic lighting technologies that will be phased out first (e.g. 60W and 100W screw and bayonet) and over time
(iii) The timescales required for supplies to meet demand for new products
(iv) The medical exemptions required for those that suffer from light sensitivity conditions such as lupus and how these exemptions should be implemented (e.g. via retailers or doctors).
(v) The specialist exemptions required and how these should be implemented (e.g. photographic or cooker lights)
(vi) The legislative and tax measures required to ensure that LEDs rapidly come down in price and are able to offer consumers 90%+ energy savings.

The manufacturers have investments to protect and should not be relied upon to provide objective assessments on the types of innovation and levels of supplies that can be achieved if markets for products offering high levels of energy performance were created.

3. User-orientated performance standards

Different makes and designs of CFL vary considerably in their light quality, energy performance, mercury content, UV radiation, build quality, compactness and lifetime.

It is important that the EU creates minimum standards and enforcement mechanisms for CFLs designed to ensure that all CFLs on sale in the EU meet the expectations of the end user.

The best CFL designs already offer a high level of energy performance and user experience, but it can be difficult for consumers to discriminate between good and bad CFLs. The dumping of poor quality CFLs will need to be pro-actively blocked by the usual trade and enforcement mechanisms. Consumer choice should be assisted by the use of clear and helpful energy labels, which may need to be recalibrated upwards.

4. Rationale for a high level of energy efficiency

Climate change

According to the available science, early and significant carbon emissions offer the best means of limit the negative social and environmental impacts of climate change and the economic costs associated with adaptation.

Energy security

With the EU’s supplies of oil and natural gas running out faster than expected and increased energy imports coming from Russia and the Middle East it makes sense to
reduce energy demand and to increase energy security and energy independence through the installation of efficient energy using products.

Economic efficiency and competitiveness

If the EU’s domestic light bulbs were more energy efficient this would make the European economy more efficient and competitive.

If it proves impossible to introduce bold energy performance standards for domestic light bulbs it is unlikely that other countries and technologies will achieve significant improvements in energy efficiency.

China

Most light bulbs are now produced in China and it unlikely that light bulb production will return to the EU.

China has announced plans to phase out the manufacture of incandescent light bulbs and can be expected to continue climbing up the technological and value chains.

Peak electricity demand

Lights tend to be on during periods of peak electricity demand and to play a major part in determining the total amount of installed capacity of electricity generators that all EU nations require. As a result, domestic lights tend to use some of the most expensive electricity produced on a daily basis.

Fuel poverty

With 500 million people in the EU facing increased energy bills, removing wasteful energy use through the implementation of ambitious energy performance standards for domestic light bulbs would help to reduce fuel poverty and to accelerate the recovery from the present economic recession.

5. Overview of Ban The Bulb proposals

CFL and LED based minimum standards

CFLs already offer 65% - 80% energy savings whilst dimmable LEDs already offer 90% energy savings for table and floor lamps when compared to equivalent domestic incandescent light bulbs.

Non-dimmable designs (90% of the market) : next 3-5 years

CFLs should represent the minimum energy performance standard for the majority of domestic lights, which do not need to be dimmed within 3-5 years.

Dimmable light bulbs (10% of the market) : next 3-5 years

LEDs should represent the minimum energy performance standard for all dimmable domestic light bulbs within 5 years.

The niche requirement for light bulbs to be dimmed should not be allowed to hold back energy performance across the entire domestic lighting sector and equivalent dimmable technologies should have no purchase price advantage over CFLs.

If dimmable lights are to be permitted to make up a minor proportion of the lighting market they should offer the best energy performance possible today (e.g. a 45% saving relative to incandescents).

Halogen lamps with an infra-red coating (Class B), which can be dimmed and offer 45% energy savings, should only be allowed where CFLs are inappropriate and should be replaced by dimmable LEDs within the next 5 years.

All domestic light bulbs (100% of the market) : within 5 years

LEDs should provide the minimum energy performance standard for all domestic lighting within 5 years.

Supporting legislation

The EU should consider using all of the means at its disposal to ensure that the diversity and volume of LEDs on the market is significantly increased and that purchase price of LED-based lamps is reduced significantly.

6. Light bulb designs

CFLs : minimum energy performance within 3-5 years

High-quality CFLs should represent the minimum energy performance standard for the majority of easily substituted domestic lighting.

EU standards for CFLs should ensure that all CFLs on sale in the EU offer a good quality of light, are well made, produce very low levels of UV radiation and offer long lifetimes (6000 hours+).

EU standards should favour encapsulated CFL designs and spiral or stick CFLs which are certified to emit very little or no UV in order to remove the need for medical exemptions.

Any domestic light bulb designs offering energy performance below that already available from CFLs should be eliminated within 5 years.

Halogen lamps with infra-red coating (B-class) offering a 45% energy saving, and are not protected by patents, so should be used where dimmers and timers are essential and CFLs are not appropriate.

Halogen lamps with infra-red coating (Class B) : limited use for 3-5 years

Halogen lamps with infra-red coating (Class B) offer a 45% energy saving compared to incandescents, and dimmability, but should not be adopted as the new minimum energy performance standard for the majority of the domestic lighting sector or invested in further by the major manufacturers.

The light bulbs contain technologies that are not protected by patents, so should be used for roles where dimming is essential and/or CFLs are not appropriate. This technology is available to all manufacturers, but should only be allowed until dimmable LEDs become more widely available within 5 years.

LEDs : minimum energy performance within 5 years

LEDs are already available which are suitable for decorative table and floor uses and provide fully dimmable, no mercury content, instant brightness alternatives to 40W, 60W and 100W incandescents. The development of LEDs needs to be accelerated.

EU efforts should be focused on joining up its legislative, tax and market powers in ways that to ensure that LEDs are made in large numbers and become much cheaper within the next 5 years.

5W LEDs are already available as table and floor lamp substitutes to 75W incandescents. These offer instant brightness, dimmability, no mercury content, 50,000 hour lifetimes (50 times longer than incandescents), solid state resistance to knocks and vibration, intense white light, 90% energy savings.

13W LEDs are already available as table and floor lamp substitutes to 100W incandescents. These offer instant brightness, dimmability, no mercury content, 50,000 hour lifetimes, solid state resistance to knocks and vibration, intense white light, 85% energy savings.

Halogen lamps filled with Xenon gas (Class C) : very limited use for 3-5 years

Halogen lamps filled with Xenon gas (Class C) are convenient for the light bulb manufacturers, but with only a 25% improvement in energy performance do not offer adequate energy savings to be a worthwhile substitute for CFLs or LEDs beyond 3-5 years.

It is unlikely that energy efficiency standards will be revisited on a regular basis so this technology should be leap-frogged.

Other technologies, which are already available, offer dimmability, similar light qualities and better energy performance and offer a better minimum standard.

7. Lifetime costs of inefficient technologies

The lifetime costs of energy using products wasting 65% - 80% of their energy should be calculated. At present, lighting represents 10% - 15% of household electricity use and these percentages of demand could be cut to 1% - 3%. This energy saving would save the EU billons of euros on an annual basis.

The positive effects of reduced electricity demand on energy security, energy bills and the carbon emission produced by the EU’s 500 million residents should also be calculated and taken into account when deciding the costs and benefits of applying ambitious energy efficiency targets to light bulbs.

8. National Dispensation : Italy

It has been argued that Italy will find it more difficult than other nations to change the types of light bulb it uses due to the dominant type of light fitting used in this country. If this is true, then Italy could be granted a temporary dispensation from the timetable used by the rest of the EU27.

Italy should be granted no more than 1-2 years extra to act and informed of the higher energy costs it will incur by deferring greater energy efficiency. These costs should also be made public. Every effort should also be made to explore how adaptors, modified light bulbs and installation grants could be used speed up uptake in countries such as Italy.

9. Mercury / Recycling

CFLs currently contain 4-6mg of mecury and this should be reduced to 2mg within 5 years.

Mercury is a hazardous substance and covered by the EU’s RoHS Directive. The costs of recycling CFLs are currently added to the purchase price and this can be counter productive in terms of encouraging greater energy efficiency.

The most effective recycling systems that enable consumers, retailers, local governments and national government to play their roles in improving the recycling of hazardous household substances should be found and used across the EU.

10. Global production capacity

China produces 3 billion CFLs per annum and should be required to improve the quality of imports to the EU and helped to shift production towards LEDs. The phasing in of new minimum standards as appropriate new designs become available should allow supplies to match demand over several years. The total replacement of domestic light will take over 10 years and allow manufacturers to diversify their lighting products and markets.

11. VAT reduced from 17.5% to 5%

Across the EU, VAT for energy saving light bulbs that match and/or exceed the energy performance of CFLs should be reduced from 17.5% to 5%.

12. Energy labels

At present, energy labels can be hidden, small and impossible for the non-expert to understand.

Energy labels should be made simpler to understand and more useful to consumers.

In particular, energy labels should highlight running costs, energy consumption, UV radiation levels and the mercury content associated with each make and design of light bulb.

Actual and/or relative running costs for each light bulb design, compared to a standard incandescent lamp, should be highlighted on packaging.

13. Fuel poverty

Light bulb manufacturers should be encouraged to invest research and development and helped to invest in significant manufacturing capacity for the most energy efficient light bulb. The EU should not subsidise any light bulbs designs less efficient than CFLs.

The economies of scale offer the best route to cheap LEDs and it is essential that high quality CFLs and cheap LEDs are brought to market as quickly as possible.

Efforts to distribute energy saving light bulbs for free should be considered but it would be more effective to remove wasteful designs from the market and to subsidise energy efficient designs in shops.

14. Building Regulations : Lumens per watt per m2

The way in which light bulbs vary and large number of halogen spotlights can be extremely profligate in their collective energy use, whilst being relatively efficient on an individual basis.

As a result, it may be necessary for the EU to update building regulations and require lights to be used in a way that offers a minimum number of lumens per watt per m2.

15. Delivering on the ambition of the EU’s 20/20/20 plan

It is important that the EU puts in place world leading energy efficiency legislation and retains a focus on reducing overall energy demand and carbon emissions by 20% by 2020 and shows that the EU is serious about making full use of the energy efficient technologies that are already available.

Other countries are highly likely to copy the energy efficiency measures put in place by the EU and a rare opportunity exists for the EU to help the 500 million people to save money on their energy bills and to show leadership to the world.

Labels: Ban The Bulb position, CFLs, halogens, infra-red, LEDs, minimum energy performance standards, xenon