Greenwashing Lamps

Comments to part III:12-17 of the EU FAQ #2.

Compact fluorescent lamp environmental impact issues

EU FAQ: III.12. Ecobalance over the life cycle

More materials and energy are needed to produce a compact fluorescent lamp than an conventional incandescent bulb, and it also results in more waste at the end of life. Does this not outweigh the benefits of its energy efficiency?

According to the technical study ordered by the Commission to prepare for the regulation on household lamps (http://www.eup4light.net/), the impact of energy savings during the use of a compact fluorescent lamp clearly outweigh the environmental impact of its production and its end-of-life. Therefore using them rather than conventional incandescent bulbs reduces the overall energy use and the environmental impact of lighting.

My comment: I’ve read this study and find it flawed, biased and questionable on more counts than I can count. Here are just a few of the more obvious points:

1. Putting clear and frosted GLS in separate classes, despite the difference in output being virtually non-existent and all other things the same, while the widely varying CFL models (bare, covered, dimmable, outdoor, daylight, improved CRI etc) with their equally varying quality levels, efficacies, applications and life spans get represented by one (!) class and (top notch) CFL type only.

2. Using unusual (average, rather than existing) lamp wattages for incandescent lamps, 54W GLS and 13W CFL as base-cases, both with incorrect lumens for their wattage-class, according to leading manufacturer catalogues.

3. Incorrect (too short) life span for typical low-voltage halogen lamps, skewing comparison with other lamp types.

4. Overly optimistic estimations of CFL recycling rates (“20%” in all of EU).

5. Like most pro-CFL ‘studies’, this one does not count the mining process for the mercury and phosphors (stating a “lack of info” on that part of the process). A reader commenting a mercury article online appears to know more: “To produce purified mercury in a CFL, the extraction process releases about 0.4mg for every milligram produced into the waterways, atmosphere, and soil as waste. This is a well-established worldwide average that includes many processes, both crude and hi-tech. This means that the 4mg in the CFL actually represents 5.6mg of mercury that enters our environment.”

6. Making distribution impact estimates on the assumption that all lamps are produced in Europe, while fully aware that most CFLs are produced in Asia:

VITO: “The distribution phase contributes more than 5 % of the life cycle impacts for 11 of the 15 environmental impact indicators. Impacts of this phase are the highest for the emission of PAHs (69 %), heavy metals (22 %), volatile organic compounds (VOC) (21 %), and particulate matter to air. This can be explained by the assumption related to transport in trucks from the retailer’s central warehouse to the shop. (…) according to the MEEuP methodology (section 5.3.6, page 96), a mix of means of transport (trucking, rail, sear freight and air freight) with assumptions on distances was used for all base-cases. This assumption could be considered as disadvantageous for lamps mainly produced in Europe (e.g. GLS-F and GLS-C) and advantageous for lamps produced in Asia (e.g. CFLi).“ [emphasis added]

7. Not including the energy used to recycle the mercury.

VITO: “Collected CFLi’s at end of life are crushed in a closed installation and sieved. The mercury containing fraction is distilated at 600°C to separate the mercury. The pure, metallic mercury is used again by lamp industry.”

8. Not including all the forced individual driving to remote recycling stations for householders who wish to leave their CFLs for recycling, or to the few retailers who have a recycling program, and then from them to the recycling stations, then transportation from recycling stations to reprocessing factories and from reprocessing factories back to the lamp factories. As Dr Peter Thornes points out on his website, when the lamp industry has their CFL production located in China, that’s where the mercury has to be shipped back to:

“However, it is not just the energy requiring manufacture (after all, CFLs have longer lifespans, which gives some compensation). It is also the greater emissions from their longer transport from the fewer centra in which CFLs are economical to make (China), and it is also the further CFL transport emissions to recycling plants and the emissions of their reprocessing there, and the further transport of reprocessed parts to different locations. This means that inter-continental transport between China and North America/Europe can take place twice, since CFL content including mercury may be shipped back to China for reprocessing and new manufacture. Even more significantly, shipping use of bunker oil, the worst CO2 emitting type of oil, greatly increases the emissions involved (more).”

Sounds like an awful lot of driving, shipping, processing and polluting, doesn’t it?

9. Not including the future costs of brain damaged babies, learning disabled children or lowered general health and mental function of coming generations through slow mercury poisoning of the entire population after millions of CFLs end up in landfills.

III.13. No need to remain on to save energy

Is it true that because of high energy use at start-up, compact fluorescent lamps have to remain switched on for 45 minutes before they bring any energy saving at all?

It is not true that energy saving lamps do not provide energy savings when switched on only briefly. The energy use of compact fluorescent lamps in the first 2 to 3 seconds of their operation is slightly higher, but after that their power uptake is stabilised. In practice, they provide energy savings compared to incandescent bulbs right from the moment they are switched on. Nevertheless, compact fluorescent lamps might not be the proper choices for some applications. If the lamp is switched on both briefly and rarely, the energy savings will counterbalance the higher purchase price of the lamp only very slowly, over several years or even decades. In such a case the much cheaper improved incandescent bulbs with halogen technology should be used. If the lamp is switched on briefly and frequently, it may reduce the lifetime in the case of some compact fluorescent lamps. This functionality is also addressed by the regulation, requiring that compact fluorescent lamps should reach the claimed life time while being switched on/off once for every hour of operation. Where frequent on/off switching is likely, dedicated compact fluorescent lamps that can endure up to 1 million switching cycles, or other energy saving light sources insensitive to switching can be used (such as improved incandescent bulbs with halogen technology which will also remain available). If this is a feature consumers are concerned about, they should look out for the information on the product packaging, where the manufacturers will be required to display the number of times the lamp can be switched on before failure.

In other words, this still is a problem with many CFLs, so use standard CFLs only in lamps that you usually have turned on for longer periods at a time.

III.14. Mercury content and the environment

Compact fluorescent lamps contain mercury, a hazardous material, conventional incandescent bulbs do not. If more compact fluorescent lamps are used, does it not mean more mercury pollution in the EU?

Mercury is present in compact fluorescent lamps in such a small amount that during its lifetime a compact fluorescent lamp (CFL) will have saved more mercury emissions from electricity production in coal power plants (compared to the mercury emissions related to the conventional incandescent bulbs’ electricity need) than is contained in the CFL itself.

This clever PR argument was created in 1991 as part of the organised global anti-lightbulb campaign. It was based on Danish coal use which at that time was the highest in Europe (95%) and a ridiculously low theoretical CFL mercury content of only 0.69 mg. EU as a whole uses much less coal now (29%), and some contries none at all. (See my post Mercury problem increasing for more details.)

Even incandescent-hating consultant firm VITO, when trying their best to find fault with the incandescent lamp and benefits in CFLs in the preparatory study, was unable to produce more than the most marginal Hg reduction (10.9%) when comparing the best performing CFL base-case with the poorest performing GLS base-case and assuming a Hg content of 4mg and an optimistic recycling rate of 20% across EU. Considering the fact that most CFLs used at home don’t perform nearly as well or last as long as the nominal values for that state-of-the-art naked tube CFL (as measured after 100 burning hours in optimal lab conditions, at optimal temperature and burning position wihtout shades) which is always used as base-case CFL, one can safely assume even this small number to be exaggerated as well.

If one wishes to stop mercury emissions, the most logical thing would be to phase out the use of coal (and gold mining!) rather than phasing out an arbitrarily chosen consumer product that uses less than 1% of total energy consumption and contains no toxic substances on its own.

Moreover, CFLs should be recycled according to EU legislation already in place.

Yes, they should. But, as I’ve pointed out before, “should” does not mean they will be. Some have more pressing matters on their daily agenda than safely recycling their lamps. Even in countries with good recycling schemes many peope aren’t aware that CFLs should be recycled (about half the Danes did not know this as of January 2009). Getting them to a recycling station for hazardous goods is no easy thing, especially if you’re elderly or don’t have a car. (See my post about Recycling)

Mercury is an important component of compact fluorescent lamps (CFLs) that plays a key role in their energy efficiency and also other parameters such as lifetime and warm-up times. There are up to 5 milligrams (0,005 grams) of mercury contained in a CFL (compared to 50 milligrams in button batteries, 500 milligrams in dental amalgam filling or several grams in older thermometers). The 5 mg limit is set in the Restriction on Hazardous Substances Directive (2002/95/EC), which in general forbids mercury in electric and electronic equipment, but provides some exemptions in duly motivated cases. The limit is enforced by Member States equally on all bulbs, whether they are cheap Chinese ones or produced by European manufacturers.

But even the Commission’s own consultants in their Domestic Lighting Study found one sample of five tested to contain 6.4 mg – assumed due to manual hand-dripping in Chines non-automated factories – and the Maine DEP found a range of 0.9 to 18 mg! Mercury in CFLs

Compact fluorescent lamps have been widely used in European homes in the past decade, they will not be introduced by this regulation.

But they will be more or less mandated by this regulation as they are not used widely enough in the Commission’s opinion.

Most office and public buildings, and also most streets have been equipped for the last 50 years with fluorescent and high-intensity discharge lamps containing mercury (often much more than compact fluorescent lamps).

But in in public buildings and street lights, the lamps are placed much higher in luminaires that cannot be knocked over, and there are usually routines for recycling them properly after use. But they are of course only safe as long as there are no earth quakes, fires or other disasters. After the 9/11 attack on New York, rescue workers have been getting sick, some from mercury poisoning! Assumably from all the florescent lights breaking as the twin towers went down.

Gotham Gazette: “Detective James Zadroga was inside 7 World Trade Center on the morning of September 11, 2001. He escaped –- barely –- when the building collapsed. But Zadroga could not escape the damage done to his body by the hundreds of hours he spent at Ground Zero cleaning up the rubble in the following weeks. On January 5 of this year, Zadroga died from lung disease and mercury poisoning – a condition that hasn’t been a widespread occupational hazard for over a century when hatters were sickened as they dyed beaver pelts.”

The Heroes Of 9/11 Are Getting Sick

The directive only mandates shops to take back CFLs and other electronics if one buys a new one at the same time (great way to keep consumption going). Some shops have volunteered to take them back without such strings attached, but that is their own choice. When calling around to check, many of these retailers had no idea that Hg vapourises at room temperature and had no routines for avoiding CFL breakage in recycling bins until informed of this fact! Unfortunately, I’ve not been able to provide every shop in Europe with this information. I think it is the responsibility of the Commission to make sure all are informed.

The Waste Electrical and Electronic Equipment Directive (2002/96/EC) provides for the collection and recycling of waste electrical and electronic equipments (WEEE), including lighting equipment such as compact fluorescent lamps. (…) If consumers take back their burned-out compact fluorescent lamps to collection points just as they do with batteries, the mercury content will be recycled and not released to the environment.

Member States have to ensure that users of electrical and electronic equipment are given the necessary information about the requirement not to dispose lamps as unsorted municipal waste and to collect such waste separately, as well as about the return and collection system available to them. Member States are also responsible for ensuring the availability and accessibility of collection facilities.

Quite a hefty obligation costing extra resources which poorer countries may not have!

The Commission also proposed to recast the WEEE Directive on 3 December 2008, so that the collection target for all WEEE is increased and the recycling target for gas discharge lamps is set at the level of 85%. This proposal will now go to co-decision with the Council and the European Parliament.

Good. Why not recommend a refundable recycling fee, such as already exists for bottles and cans for all goods containing toxic elements? That would surely increase recycling rates. And don’t forget to inform that CFLs must be kept from breaking!

Improved incandescent bulbs with halogen technology that do not contain any mercury are and will remain available, however they provide 25-45% energy savings compared to conventional incandescent bulbs, whereas compact fluorescent lamps save up to 80%.

Not this again! Up to 65-75% according to your own statements earlier, remember? Unless we bring things like power factor, light deprication, frequent switching and cheap imports into the calculation… then it goes down to about the level of the best halogen energy savers.

LEDs (light emitting diodes) are a rapidly emerging mercury-free technology, meeting or even surpassing compact fluorescent lamps in efficiency. However, at this stage they are not yet developed enough to be valid alternatives to the full range of household conventional incandescent bulbs (mainly available in low light outputs only, equivalent to 25W conventional incandescent bulbs).

Right. And the light colour is even worse than in CFLs.

It can be expected that in the next few years they will develop to become replacements for most existing lamps, however there is no absolute certainty about that and we need to act on climate change right away with the products that are already on the market. Nevertheless, the Commission is financing research into LEDs for general lighting through the ongoing and future calls of the EU’s 7th Research Framework Programme. The proposed regulation will be revised at the latest 5 years after adoption, and due account will be taken of the state of development of the LED market.

Good. But you’re not going to save the planet by forcing CFLs on a public which has very good reason to be reluctant! Promoting CFLs so much stronger than Halogen Energy Savers will only create more problems down the line and, as mentioned previously, is already causing a health and environmental disaster in China!

Compact fluorescent lamps and health

III.17. Effect on light sensitive people

The light produced by compact fluorescent lamps aggravates the symptoms of people suffering from auto-immune diseases such as lupus and ME. They now use conventional incandescent bulbs in their homes, if these are phased out will they be left in the dark?

The Scientific Committee on Emerging and Newly Identified Health Risks (on a mandate from the Commission services) has been looking into the question of possible health effects of compact fluorescent lamps on people with certain diseases and on the general public, following up to complaints from certain patients’ associations. The Committee examined flicker, electromagnetic fields (EMF) and ultraviolet / blue light radiation from the lamps to determine whether they aggravate the symptoms of such patients.

In its report, the Committee found no evidence that would indicate that either EMF or flicker could be a significant contributor. For the general public, very close exposure to a bare lamp (< 20 cm) for more than 8 hours could eventually affect health by exceeding workplace limits on UV emissions. This is a situation that does not occur in normal use. Hands held very close to halogen lamps or touching conventional incandescent lamps get burnt much more quickly because of the intense heat, so such a situation is not usual anyway with household lamps.

On the other hand, according to the report the symptoms of a maximum of 250.000 people in the EU suffering from diseases accompanied by light sensitivity could be aggravated in the presence of bare compact fluorescent lamps (independent of distance) due to UV and blue light emissions. Using commonly available compact fluorescent lamps with a second lamp envelope can both solve the problem of light-sensitive patients and prevent overexposure of the general public even in extreme situations. However, the envelope slightly lowers (about 10%) the efficacy of the compact fluorescent lamp, meaning more lamps using more power will be needed for the same light output. Transparent or translucid luminaires that fully cover up the bare lamps have the same effect as a second lamp envelope.

Also alternative technologies can be chosen by consumers, such as improved incandescent bulbs (with halogen technology) that have identical light spectrum to conventional incandescent bulbs.

In addition, the ecodesign regulation on non-directional household lamps introduces maximum UV emmission limit values for compact fluorescent lamps.

Good. But the estimated 250.000 light sensitive people will still be victims of the potentially aggravating naked CFLs in environments they have no personal control over, now not just in office buildings but in more and more restaurants, shops and people’s homes, restricting their lives even more than before.

III.18. No effect on epilepsy and migraine

Is it true that compact fluorescent lamps produce light through high frequency discharges causing flicker and triggering attacks on people suffering from epilepsy or migraine?

The Scientific Committee on Emerging and Newly Identified Health Risks (on a mandate from the Commission services) did not find proper evidence underpinning any negative health effects relating to flicker. The Committee examined flicker, electromagnetic fields (EMF) and ultraviolet / blue light radiation from the lamps to determine whether they aggravate the symptoms of such patients. In its report, the Committee found no evidence that would indicate that either EMF or flicker could be a significant contributor. Modern compact fluorescent lamps operate at frequencies so high that they are beyond human perception.

Hm, this is what the SCENIHR report on light sensitivity actually says:

“Fluorescent lamps can cause eye-strain and headache (Wilkins et al. 1991). Patients with migraine show somewhat lowered flicker fusion thresholds during migraine-free periods (Kowacs et al. 2004). In addition, photophobia, which is an abnormal perceptual sensitivity to light experienced by most patients with headache during and also between attacks, is documented in many studies (Main et al. 2000). People with migraine claim to be particularly sensitive to blue light (European Lamp Companies Federation). Conclusion: Migraine can be induced by flicker in general (up to about 50 Hz) and patients are light sensitive during and between attacks [Evidence level A]. Scientific support for aggravating symptoms by flicker from fluorescent tubes was not found [Evidence level D]. There is anecdotal evidence of problems with blue light [Evidence level D].”

Lack of proof is not the same as proof of non-existence. There may also be other properties to CFLs that make them ill tolerated by sensitive people, e.g. glare, fluorescence, spiky spectral distribution, dull light that causes eye strain etc.

Compact fluorescent lamps provide light that flickers at a frequency of about 60 kHz (60 000 Hz). There is consensus that flicker of such high frequency is not perceptible to the human eye. It is already doubtful whether flicker at 100 Hz can be perceived. It is true that compact fluorescent lamps produce also some weak modulation at 100 Hz, however this is not unique to this lamp type. As SCENIHR writes, also incandescent bulbs emit a low-intensity “flicker” at 100 Hz, simply because this is twice the frequency of the mains voltage electricity network (the power being delivered to the lamp peaks twice per cycle).

A. It is not at all doubtful whether flicker at 100 Hz can be perceived by some. Swedish studies have shown extra sensitive individuals to perceive flicker above the normal threshold around 90 pps (I personally know several who claim to have this debilitating superability).

B. It is true that most CFLs sold today are of the high-frequency ballast type with a 60 KHz flicker rate, far above anything even the most perceptive human would be able to see. However, there is a wide range of human sensibility and I don’t think we can exclude the possibility that the bodies of exceptionally sensitive or sensitised individuals can subliminally perceive this extremely fast flicker and react to it as a stress factor, if not as a visible modulation. Quite a large number of people report headaches, migraine, stress or general discomfort triggered by fluorescent light, I’m sure they can’t all be imagining this, even if science has yet to find a plausible explanation? People with allergies, migraines and hypersensitivities tend to eventually become very apt at noticing what factors trigger their symptoms. Why should they not be believed?

C. Just a couple of days ago I was surprised to be able to see several CFLs flickering in a dimly lit restaurant. I asked the staff about this and they said it was because the CFLs were slightly dimmed. This perceptible flicker was enough to cause a headache in an extra sensitive girl in our company.

D. Correct that incandescent lamps also flicker but as the filament keeps burning between pulses, this reduces the flicker to a more even light flow. I have yet to hear of a flicker sensitive person reacting to incandescent light.

III.19. Electromagnetic fields

Is it true that compact fluorescent lamps generate electromagnetic fields and should not be used as bedside lamps or desk lamps where they are too close to the human body?

Long answer: There is no scientific evidence of any link between the electromagnetic fields (EMF) emitted by compact fluorescents lamps and the symptoms of “electrically sensitive” people. EMF emissions from CFLs are within international limits on public exposure to EMF. Upon request of the European Commission, the Scientific Committee on Emerging and Newly Identified Health Risks (SCENIHR) has recently issued an opinion on Light Sensitivity, namely with regard to the possible aggravation of already existing symptoms of patients with certain diseases due to the use of compact fluorescent lamps.

The issue of electromagnetic hypersensitivity due to the use of such lamps has been examined. SCENIHR concluded that it has never been conclusively and convincingly shown that there exist any connections between electromagnetic fields (EMF) and the symptoms that are reported by persons with so-called electromagnetic hypersensitivity, although their symptoms are real and in many cases severe.

There is no scientific evidence of correlation between EMF from compact fluorescent lamps, and symptoms and disease states. SCENIHR also stated in its recent opinion on Health Effects of Exposure to EMF that the emissions from compact fluorescent lamps have been investigated recently and that available results showed compliance with existing limits. The levels decrease drastically beyond 30 cm from the lamps. In any case, compact fluorescent lamps available on the market have to fulfil the requirements of Directive 2006/95/EC on the harmonisation of the laws of Member States relating to electrical equipment designed for use within certain voltage limits.

Well, CFLs do emit more EMFs than incandescent lamps, I think we can agree on that, or there wouldn’t be any need for regulation. As for electrosensitivity, again I think people know their own bodies best. That studies have not been able to prove a link could be explained by poor test design, and by who gets funding to conduct such studies.

Also alternative technologies can be chosen by consumers, such as improved incandescent bulbs with halogen technology but without integrated transformer, which only generate the same type of electromagnetic fields as conventional incandescent bulbs.

Right. So class C halogens without integrated transformer need to be kept available for the allegedly electrosensitive after 2016, or they will have no option at all left, apart from candles and stinking kerosene lamps.

III.20. Mercury content and health

Compact fluorescent lamps contain mercury, which is a highly toxic substance. Do compact fluorescent lamps represent a danger to health because of that?

Mercury is an important component of compact fluorescent lamps (CFLs) that plays a key role in their energy efficiency and also other parameters such as lifetime and warm-up times. There are up to 5 milligrams (0,005 grams) of mercury contained in a CFL (compared to 50 milligrams in button batteries, 500 milligrams in dental amalgam filling or several grams in older thermometers). The 5 mg limit is set in the Restriction on Hazardous Substances Directive (2002/95/EC), which in general forbids mercury in electric and electronic equipment, but provides some exemptions in duly motivated cases. The limit is enforced by Member States equally on all bulbs, whether they are cheap Chinese ones or produced by European manufacturers.

But the Commission’s own consultants found one sample out of five to contain more than 5 mg… Who will check if all imported lamps stay within limits?

Compact fluorescent lamps have been widely used in European homes in the past decade, they will not be introduced by this regulation. Most office and public buildings, and also most streets have been equipped for the last 50 years with fluorescent and high-intensity discharge lamps containing mercury (often much more than compact fluorescent lamps).

As I’ve already pointed out, in offices lamps are are placed in the ceiling, in environments with adults only, whereas CFLs are meant to go in every possible luminaire at home if the Commission has its way, including floor and table lamps which can easily be knocked over by children, pets and at parties.

The mercury content cannot escape from CFLs, except in the event of accidental breakage of the lighting tubes. In that case less than 5 milligrams of mercury could be released.

The “5 milligrams” is an average. Some contain less, some more.

The Ecodesign regulation requires manufacturers to explain on their websites how consumers should clean debris in case the CFL’s tubes accidentally break, and to include on the packaging of each lamp the link to online explanations. Such an explanation is already available on the website of the European Lamp Companies Federation. In short, if the lamp breaks accidentally, if possible air the room before cleaning the lamp with a wet cloth, avoid skin contact with debris and do not use a vacuum cleaner.

Assumably this one: ELC Mercury Factsheet (not easy to find on their website). Let’s see what it says:

“Since energy saving fluorescent lamps are made of glass, care should be taken when handling them. Always screw and unscrew the lamp by its base, and do not forcefully twist the lamp into a light socket by its tube. Breaking an energy saving fluorescent lamp is extremely unlikely to have any impact on your health. Proper cleanup and adequate ventilation minimize the impact even further. If a lamp breaks, switch off the electricity and ventilate the room for 20-30 minutes. Broken lamps should be removed, preferably with protective gloves, and be placed in a sealed plastic bag in the disposal bin. Avoid using the vacuum cleaner to remove the broken parts.”

Not a very impressive clean-up guide… It downplays both proven dangers of mercury and the contamination level that may occur. The Maine DEP tests found that:

“Mercury concentration in the study room air often exceeds the Maine Ambient Air Guideline (MAAG) of 300 nanograms per cubic meter (ng/m3) for some period of time, with short excursions over 25,000 ng/m3, sometimes over 50,000 ng/m3, and possibly over 100,000 ng/m3 from the breakage of a single compact fluorescent lamp” “Although following the pre-study cleanup guidance produces visibly clean flooring surfaces for both wood and carpets (shag and short nap), all types of flooring surfaces tested can retain mercury sources even when visibly clean. Flooring surfaces, once visibly clean, can emit mercury immediately at the source that can be greater than 50,000 ng/m3. Flooring surfaces that still contain mercury sources emit more mercury when agitated than when not agitated. This mercury source in the carpeting has particular significance for children rolling around on a floor, babies crawling, or non mobile infants placed on the floor.” *

The ELC also gives incorrect (=dangerous) advice about debris storage! The Maine DEP testing found plastic bags and even plastic containers to be insufficient to prevent Hg vapour leaking out and contaminating everything around.

“Surprisingly, plastic jars, like large peanut butter containers with screw top lids were little better than plastic bags, also failing to prevent mercury vapour from leaking into the house. The best method of containing bulb waste is inside a glass jar with a hermetically sealed lid.”

Mercury in CFLs

Should EU not have the same recommendations; that

“homeowners consider not utilizing fluorescent lamps in situations where they could easily be broken, in bedrooms used by infants, small children or pregnant women, or over carpets in rooms frequented by infants, small children or pregnant women.”

And will EU require a label on the box stating the mercury content, warning about use around children pregnant women and explaining what to do and not to do in case of an accident?

Buying commonly available CFLs with an outer non-breakable lamp envelope is another way to address the issue of mercury leakage in case of accidental lamp breakage.

Right. So why not ban any CFL that has not got a non-breakable envelope and amalgam technology to keep people and the environment safe? Because some of the major producers don’t have such an option yet? Or because that would make the CFLs more expensive and slightly less efficient, which is more important issues than people’s health..?

Consumers who would particularly worry about mercury can choose alternative technologies such as improved incandescent bulbs with halogen technology, which do not contain mercury.

Not if they want a frosted bulb, as all frosted bulbs are now banned.

III.22 Light spectrum and public health (UV, hormones, cancer etc)

Does the specific light spectrum of compact fluorescent lamps make them a threat to public health?

The Scientific Committee on Emerging and Newly Identified Health Risks (on a mandate from the Commission services) has been looking into the question of possible health effects of compact fluorescent lamps on people with certain diseases and on the general public, following up to complaints from certain patients’ associations. In its opinion, the Committee concluded that for the general public, very close and prolonged exposure to a bare lamp (< 20 cm) could possibly affect health by exceeding workplace limits on UV emissions. According to the United Kingdom’s Health Protection Agency, less than 10% of the bare lamps exceed workplace limits in 8 hours of exposure at 20 cms from the lamp 14 , and none in 4 hours. This is a situation that is not very likely to occur during normal use, as experience with today’s household lamps suggests.

Earlier studies have found an increased risk for melanoma on some working people working indoors under fluorescent tubes in the ceiling, compared with people not working under FL.

Malignant melanoma and the exposure to fluorescent lighting at wo

The Association of Cutaneous Malignant Melanoma and Fluorescent Light Exposure

III.23. Safety issues and signs of end of life

Are compact fluorescent lamps safe for use? Is it normal if there is a bad odour or smoke when they are switched on, or if they emit an audible noise?

Compact fluorescent lamps placed on the EU market have to comply with the product safety legislation of the EU (notably the General Product Safety Directive 2001/95/EC and the Low Voltage Directive 2006/95/EC). Industry and international standardisation organizations established harmonised safety standards for compact fluorescent lamps many years ago and are periodically reviewing them. These standards provide presumption of conformity with product safety legislation in the EU. Compact fluorescent lamps should be replaced at the first sign of any odour, smoke, audible noise, or in case of erratic behavior such as flashing, flickering that may indicate an electrical component failure. If this happens clearly before the lifetime indicated on the packaging has elapsed, the lamp should be returned to the manufacturer or retailer for possible further analysis.

Good advice! Doesn’t make them sound very safe, though.

Here are comments to part III:1-11 of the FAQ#2. Part II was not relevant enough to comment, but anyone interested can read it for themselves here.

EU FAQ: III. Compact Fluorescent Lamp issues

III.1. Advantage of using compact fluorescent lamps

A compact fluorescent lamp offers:
- up to 80% energy saving compared to an conventional incandescent bulb
- about 60 € cost savings over its lifetime
- a lifetime of at least 6-10 years (compared to 1-2 years for conventional incandescent bulbs)
- no risk of burning due to the lamp’s operating temperature
- a wider choice of colour temperatures (cool or warm light, conventional incandescent bulbs can only be warm light)

Still desperately trying to find something good to say about the CFL, I see, as if the Commission were actually selling them instead of just defending an unpopular law. Well, we’ve already established that the best save theoretically 66-75%, in reality even less with all the below mentioned factors included. Thus, the other calculations must be adjusted downwards to reflect this.

III.3. Quantity of light

Is it true that compact fluorescent lamps produce less light than conventional incandescents?

Compact fluorescent lamps can produce just as much light as conventional incandescent bulbs. Consumers should check the product packaging to buy lamps of the appropriate power and light output. Currently, exaggerated claims are often made on the packaging about the light output of compact fluorescent lamps (e.g. that a 11-12 Watt compact fluorescent lamp would be the equivalent of a 60 Watt conventional incandescent, which is not true). The regulation will introduce restrictions on equivalence claims made on the product packaging, in order to keep the claims reasonable.

This is good! Will the Commission also quit making false claims about “80% savings” which, as mentioned in your own quote, is not true. (Only if an 11-12W CFL gave as much light as a 60W GLS would this be accurate.)

III.4. Lifetime

Is it true that compact fluorescent lamps have a much shorter life time than generally claimed?

Untrue. There are indeed low quality compact fluorescent lamps that do not reach their normal life time (6000 h), but most respect the claimed values in average domestic use.

Sources to back up this “most”, please. Life rates achieved in optimal lab conditions may be very different from those conditions encountered in homes…

The regulation introduces requirements on lifetime so that national market surveillance can eliminate free-runners.

Who will be doing the checking? I’ve been informed that quality tests are made in China, not in Europe. Will those that don’t pass the tests be banned from import and sales in Europe? Will those who make exaggerated claims be fined?

III.5. Switching frequency

Is it true that compact fluorescent lamps should not be switched on/off frequently because it shortens their lifetime? For example, does it make sense to install them in a toilet which is used for 5 minutes 10 times a day?

It is true that frequent switching reduces the lifetime of some compact fluorescent lamps. This functionality is also addressed by the regulation, requiring that compact fluorescent lamps should reach the claimed life time while being switched on/off once for every hour of operation. Where frequent on/off switching is likely, dedicated compact fluorescent lamps that can endure up to 1 million switching cycles, or other energy saving light sources insensitive to switching can be used (such as improved incandescent bulbs with halogen technology which will also remain available). If this is a feature consumers are concerned about, they should look out for the information on the product packaging, where the manufacturers will be required to display the number of times the lamp can be switched on before failure.

Short translation: Yes, it is true. That CFL life may be shortened by up to 85% by being switched on and off frequently, according to Osram and Chen W, Davis R, and Ji Y. 1998. “An Investigation of the Effect of Operating Cycles on the Life of Compact Fluorescent Lamps” which found that when the length of time the lamps were on was reduced from 3 hours to 1 hour, the lamp lasted for 80 percent of its rated life. When reduced to 15 min and 5 min, the lamp lasted for 30 percent and 15 percent, respectively, of its rated life.

As most of us don’t have and many possibly can’t afford the new and improved CFLs of higher quality that can withstand frequent switching, this means that in reality CFLs used at home and turned on and off many times a day do not last as long as their rated life. Consumer complaints all over the internet appear to support this assumption.

III.6. Dimmability

Is it true that compact fluorescent lamps cannot be dimmed?

Untrue, there are compact fluorescent lamps on the market that can be dimmed, and there are dimmers that can dim any compact fluorescent lamp. Consumers should carefully read product information concerning dimmability.

Most CFLs still cannot be dimmed. The few dimmable CFLs are a) hard to find; b) cost up to 20€; c) will not create that warm candle-like light like dimming incandescents does, but just make the already poorer quality light even more grey and dull than it already is. The only advantage is that you can use them in existing dimmable luminaires without destroying both lamp and luminaire and causing a fire hazard.

Improved incandescent bulbs with halogen technology will also remain available and provide full dimmability in all circumstances.

Not frosted halogens.

III.7. Starting and warm up times

Do compact fluorescent lamps really take longer to switch on and warm up to full light output than conventional incandescent lamps?

True. In order to guarantee an acceptable level of service with any compact fluorescent lamp, the regulation introduces minimum requirements on switch-on and warm-up times. Switching on a compact fluorescent lamp shall not take more than 2 seconds, and it should reach 60% of its full light output within one minute. However, there are now compact fluorescent lamps on the market that come close to conventional incandescent bulbs for these performance parameters from the point of view of the average consumer. If these are features consumers are concerned about, they should look out for the information on the product packaging, where the manufacturers will be required to display warmup-times.

An awful lot of things consumers need to educate themselves on, or ask well informed staff about, in order to get the right bulb for the right application. Before CFLs, you could just grab a bulb at the supermarket and stick it anywhere without problem. All you needed to know was watts and socket type.

Improved incandescent bulbs with halogen technology will also remain available and provide full light ouput instantly.

Not frosted.

III.8. Shape and light quality

Isn’t the shape of compact fluorescent lamps ugly and do they not produce unpleasant light (also in terms of colour rendering, colour temperature and light spectrum)?

Consumers usually find modern quality CFLs perfectly suitable for everyday tasks and aesthetically pleasing.

Eh, no. If this was true, there would be no customer complaints, there would be no objection to this regulation, or indeed a need for it at all, and people would not be hoarding incandescent bulbs in desperation.

Yes, they keep getting better, but that’s still not good enough. I keep checking state-of-the-art CFLs and LEDs just to make sure I’m not missing any acceptable replacements, but I have yet to find one that gives the same light as an incandescent or halogen.

There may be some substandard compact fluorescent lamps on the market, but those will be removed through the functionality requirements of the regulation.

Well, some are worse than others, yes, but all standard CFLs, even from leading manufacturers, have suboptimal colour rendering (CRI 82-85) and give a dull and dead light compared to incandescent/halogen.

Improved incandescent bulbs with halogen technology will also remain available and produce exactly the same light quality as conventional incandescent bulbs.

Yes they do, but you’ve already banned frosted halogens and want to phase out most of the rest too.

Overall, the perception of shape and light quality is quite subjective, however there are parameters that can be measured. On some of these parameters, CFLs are actually doing better than conventional incandescent bulbs and halogens.

Really now? Well, let’s see:

Size and shape

Modern CFLs come in a variety of sizes and shapes approaching that of conventional incandescent bulbs. The outer lamp envelope that hides the small twisted lighting tubes has become commonplace, and makes CFLs resemble frosted (non-transparent) conventional incandescent bulbs in appearance.

This is mainly an aestetic advantage to make them look and function more like a traditional bulb. But the outer bulb also makes them less efficient and durable so this isn’t what the Commission really wants us to use, it just sounds good to be able to use this example in reply to complaints about fit and look.

Colour rendering

In order to ensure proper colour rendering (ability to reproduce the colours of the objects lit) for CFLs, the regulation introduces a minimum requirement on this product parameter.

Which I assume will be CRI between 80 and 85 (= mediocre) as higher CRI means adding more phosphors, making them more expensive?

Colour temperature

CFLs can be produced with different colour temperatures (warm/cold) depending on consumer needs, whereas conventional incandescent lamps can only provide warm white light.

Here in the North that warm light is much appreciated, but those who still prefer a cooler light should use white LEDs as WLEDs are naturally cool-white without the added phosphor coating to make it almost-warm-white. LEDs also last longer, can often be dimmed and contain no mercury. No reason to use CFLs for this. For professional colour discrimination uses, there is also the halogen Solux lamp.

The regulation requires the indication of colour temperature on the lamp’s packaging, so consumers should watch out for this information.

Good. Even if it is another thing the consumers have to educate themselves on. One thing that is not so good is that manufacturers can claim same Correlated Colour Temperature as incandescent light = “same light”. But same CCT does not say anything about light quality or actual light colour. A pink-white CFL or green-white LED can have a CCT of 2700K and still not look at all like the golden-white light from an incandescent. Just like CFLs and LEDs can have a CCT of 5000K and still produce a very different colour than the warmish neutral-white of real sunlight.

Light spectrum

If natural daylight is taken as a reference, both conventional incandescent bulbs and compact fluorescent lamps fail to imitate it perfectly, but for different reasons. Natural daylight has a spectrum which is a continuous curve, as strong at the blue and ultraviolet wavelengths as at the yellow and red wavelengths. The light of conventional incandescent bulbs has a continuous spectrum, however it has very little blue component and an extremely high proportion of red and infrared component, therefore it is very yellow and most of it is emitted as heat.

Incandescent light is golden-white and the eye adjusts. As there are no gaps in the spectrum, all colours can be seen. How well depends somewhat on how bright it is, as incandescent light gets whiter at higher wattages.

The spectrum of compact fluorescent lamps differs from natural daylight in that it is not a continuous curve. They emit a high amount of light at certain wavelengths and almost nothing at adjacent wavelengths.

Correct. Which makes colours look rather dull, in comparison with how they look in incandescent light. Do try a direct comparison for yourself. (Yes, you too, commissioners, so you can see with your own eyes what you’re phasing out.) And do try with the back of a CD to see how much of the spectrum you can see under various lamps.

However, in terms of the proportion of light emitted within the blue and red wavelength ranges, there are compact fluorescent lamps that are able to reproduce daylight more precisely than conventional incandescent bulbs.

Those special superduperexpensive ‘full-spectrum’ lamps? I’ve tried them when working with colours and found them lacking. The best I’ve tried for true colour rendering was a 150W halogen floodlight and of course real daylight. Both of which have higher CRI and colour rendering capacity than even the best CFLs.

III.10. Is it true that compact fluorescent lamps do not work in cold temperatures?

A standard compact fluorescent lamp will indeed lose a substantial part of its light output in cold temperatures. However, there exist compact fluorescent lamps designed specifically for outdoor use which can withstand cold temperatures without losing performance. Consumers should watch out for this information (required by the regulation for display on the packaging) when purchasing compact fluorescent lamps. Improved incandescent bulbs with halogen technology will also remain available and can operate in any ambient temperature.

Great… more things to look out for…

III.11. Price

Aren’t compact fluorescent lamps much more expensive than conventional incandescent bulbs?

Compact fluorescent lamps are actually much cheaper than conventional incandescent bulbs if you consider also lamp life time and costs related to electricity consumption while using the lamps. During the lifetime of one compact fluorescent lamp you will have used 6-10 conventional incandescent lamps. And the compact fluorescent lamp will consume one fourth / one fifth of the electricity consumed by conventional incandescents, another cost saver. A six-year-life energy-saving bulb would save about €36 during its lifetime (60W conventional incandescent versus 15W compact fluorescent lamp). This is based on an assumption of 3 continuous burning hours per day, for an energy cost of 0,136 €/kWh. The initial difference in the lamp price is paid back in 8 months through electricity savings and because of the distribution of the product cost over a longer lifetime (assuming a price of 4,50 € for the compact fluorescent lamp and 60 cents for incandescent bulb).

Hm, but if one has switched the CFL on-and-off too often (due to not being informed of the 15-minute-on recommendation), or used it in a closed or recessed luminaire (due to not having been informed that it may get overheated), or it loses too much output after a while so that it has to be replaced long before it burns out (and not having been informed that one should buy a 20W to compensate for the inevitable gradual loss that all CFLs suffer from), or one got a poor quality CFL at the local gas station that only lasted half the promised life, this rather cuts expected savings too, doesn’t it?

After the massive critique following the dedcision to phase out standard incandescent lamps in favor of problem-ridden CFLs, the European Commission some months ago obviously found it necessary to issue another FAQ explaining the details and rationale behind the decision and answering some of the many justified questions posed by us critics.

This one is if possible even longer and more verbose than the first FAQ that I commented on in March, so I’ll have to take this one in installments and still leave some parts out as it keeps repeating the same phrases over and over, probably in an attempt to overwhelm the reader into submission and acceptance of the unacceptable.

EU FAQ: I.1. Political motivation for the phase-out

Why is it necessary to phase-out conventional incandescent bulbs?

The European Union remains committed to achieving its objectives in the fight against climate change, including the reduction of primary energy use by 20% compared to business as usual by 2020. Requirements on the energy efficiency of products are a cornerstone of the Community policy aiming to achieve this target. Lighting may represent up to a fifth of a household’s electricity consumption. There is a four to five-fold difference between the energy consumption of the least efficient and the most efficient lighting technologies available on the market. This means that upgrading the lamps could reduce a household’s total electricity consumption by up to 10-15% and save easily 50€ / year (taking into account the purchasing cost of lamps).

My comment: a. According to statements elsewhere in this FAQ, the Commission acknowledges the fact that there is a max 4-fold difference (and more if you bring poor power factor, light deprecation and other factors also admitted by industry and Commission both). However, the “4-5-fold” argument was used to sell the ban to politicians so I guess they feel a need to stick to it. Or they don’t understand the issue well enough themselves, which is quite possible.

b. Lighting is an average of 10% of home electricity in EU, and electricity in turn is only 8.5% of total EU energy use, making lighting 0.75% of total. Of this, only around half the lamp stock is still incandescent, according to the Commission’s own consultants. Half of 0.76% of = 0.38%. Of these 0.38% the EC hopes to save 65-75%, which would be 0.25-0.28% of EU total energy consumption if all lamps were replaceable with CFLs and if CFLs really saved that much, which is not the case. This is not very close to the “saving 20% by 2020″ goal is it?

Section I.2. contains a description with pictures of what types of lamps will be banned and when. Short summary:

- Last (lowest wattage) standard incandescent banned by 2012.

- Affordable look-alike class C Halogen Energy Savers will be permitted until 2016. (Frosted ones are already banned, though.)

- After 2016 only the super-expensive and hard-to-find Class B Halogen Energy Savers with infrared coating and integrated transformers will be permitted as replacement lamps for standard incandescents.

- Also permitted after 2016 will be more efficient “special cap” halogen lamps, e.g. those mini-bulbs that go in halogen spotlights and the thin double-ended tubes that go in floodlight luminaires. My comment: Good! I was worried there for a while that all of those would disappear from the market with no replacements to fit in existing downlight-, uplight-, spotlight and floodlight luminaires. If the added xenon makes these more efficient than standard halogen lamps, even better.

- CFLs and LEDs will also be permitted after 2016, the latter expected to become viable alternatives in the near future as their brightness, affordability and quality improve.

D. Compact fluorescent lamps (CFLs)

Its main interest lies in its long lifetime and high efficiency, the lamp will use between 65% and 80% less energy (from a third up to the fifth of the energy) for the same light output compared to conventional incandescents.

I already pointed out in my comments to the first FAQ that you cannot claim a lamp “saves 80%” when you in the very same FAQ acknowledge the fact that:

“Today, the same quantity of light (around 750 lumens) can be produced by an incandescent bulb using 60 W, a halogen bulb using 42 W, or a compact fluorescent lamp using 15 W.”

This means 75% not 80%.

It sometimes comes with an external envelope which hides the tubes and makes it even more similar to light bulbs (though decreasing its efficiency). The envelope also shields off any unwanted ultaviolet radiations and mitigates the risks connected to mercury emissions because of lamp breakage (especially if it is made of non-breakable silicone). CFLs can live between 6000 and 15000 hours, depending on type and use (as opposed to 1000 hours for an incandescent bulb).
The enveloped bulb type is harder to make long-life due to heat buildup within the outer bulb, loses more output with age and is somewhat less efficient. The Eco-Design group and its consultants already know this, yet always recommend this outer bulb type as the solution to complaints about mercury, UV, harsh light etc., while at the same time basing all savings estimates on the performance of the best, top brand, naked tube CFLs under optimal lab conditions, compared with the poorest performing incandescent!

This strikes me as manipulaitve and outright dishonest. And fooling not only fellow politicians, media and the average Joe, but also themselves, as their projections for how to meet the 2020 goal will turn out to be the fantasy it is when based on skewed calculations rather than on complex reality.

I.3. Ambition level for frosted lamps
Why go for class A and ban even class C/B frosted bulbs from the market?

During the preparatory process leading to the adoption of the Regulation, the analysis showed that among frosted lamps which diffuse light, there was reason to require the highest level of efficiency corresponding to class A of the EU energy label for lamps. 2 This level of efficiency is achievable by compact fluorescent lamps and by light emitting diode lamps. The type of soft light provided by frosted incandescent bulbs and by compact fluorescent lamps does not differ substantially for the average consumer, therefore the more efficient technology can easily replace the other.

But it does differ substantially. See my post about light quality: http://greenerlights.blogspot.com/2009/03/3a-cfl-analysis-light-quality.html There is NO lamp left on the market which can replace the frosted incandescent lamp. CFL and LED lamps do not produce the same light quality, this should be visible to anyone who is not colour blind, besides being measurable by spectral analysis.

Clearly, this measure was taken in order to force that majority who prefer non-glaring frosted lamps to buy CFLs instead, by removing all frosted alternatives, including frosted Halogen Energy Savers!

For those who really cannot tolerate the substandard light quality of CFLs and LEDs, I strongly urge the Commission to reconsider this hasty decision and permit frosted Halogen Energy Savers. There is no reason whatsoever to ban those. People should have a free choice which energy saver they prefer to use.

The frosted halogen lamp is excellent for reading, for example, while clear lamps cause glare and disturbing patterns on the page. Removing all frosted incandescent and halogen lamps from the market creates a gap that no other lamp can fill, leaving elderly and vision impaired literally in the dark.

However, sometimes consumers look for the particular light quality/aesthetics delivered by transparent lamps, which provide a bright point-like light, useful e.g. in crystal chandeliers. For these applications, there is a need to keep alternatives to compact fluorescent lamps, which cannot deliver the same type of light. This means leaving less efficient, but still enhanced incandescent bulbs (of the halogen type) on the market, at least as long as there is no more efficient technology that can replace them.

Glad that the Commission recognises this at least.

Such lamps also provide alternatives for the few situations where the use of compact fluorescent lamps is not recommended due to practical reasons (such as in locations where the light is switched on rarely and for a short time only).

Non-glaring frosted Halogen Energy Savers would have been a nice option to have. Here the Commission has removed a whole product group without there being a useful alternative for elderly, vision impaired and others who need frosted incandescent light in order to see well without being blinded.

I.4. Ambition level for clear lamps

Why is the minimum efficiency requirement not raised to class A for clear (transparent) lamps too?

The requirement on clear lamps is only raised to class C until 2016 (and to class B beyond 2016), so that other efficient technologies (such as improved incandescent bulbs with halogen technology) can remain on the market. This is necessary because current-day compact fluorescent lamps and light emitting diodes cannot provide the same type of light as the conventional incandescent lamps that are being phased out.

However improved incandescent bulbs with halogen technology do, and consumers who are keen on conventional incandescent light quality for aesthetics or health reasons should have access to it.

Yes, they should. So bring back the frosted halogens!

I.5. Proportionality of the phase-out – why not voluntary approach or other measures (taxation, ETS)

Is it not disproportionate that the European Commission bans conventional incandescent bulbs from the market? Would it not be better to leave the choice to citizens or to make use of other measures to achieve the switch (such as voluntary restrictions as in the UK, information to the public or taxation)? Isn’t the EU’s Emissions Trading System (ETS) anyway supposed to take care of the emissions related to electricity generation? Does ETS not affect consumer choices already indirectly, through price mechanisms?

The European Commission did not decide on its own to phase out conventional incandescent bulbs, it is done in agreement with the European Parliament and with the Council of Member States.

So, after singlehandedly pushing this ban with extreme fervour, hiring consultants who appear to hate incandescent light with a passion and are only too happy to produce a questionable preparatory study that supports a ban, and issuing a totally misleading Technical Briefing that gave voting politicians the faulty impression that this measure will save 10-15% of the 20% goal rather than 0.25%, you now want the Parliament and Council to share the blame?!

Introducing minimum efficiency requirements for a product group such as light bulbs (rather than relying on a voluntary approach) is not disproportionate in this case. The market has clearly failed to move towards the alternatives to conventional incandescent bulbs, even though they cost much less to the consumers over their entire life cycle.

Because the main product pushed is inferior compared with incandescent lamps. It is truly as simple as that. People are not stupid. If it was a great product it would sell itself! Forcing a lower-quality product on people against their will is truly bizarre! Especially when lighting is so vital both for mood and ergonomics, it’s not like regulating aquarium pumps or water beds which most can surely do without.

The European Union’s Emissions Trading System (ETS) directly affects the emissions of electricity generation, however there is cost-effective saving potential also in the reduction of electricity use of households, which cannot be directly achieved through ETS. Although the indirect impact of the ETS could translate into an increase in electricity prices and therefore in the use-phase costs of an incandescent bulb, such an increase would have to be multi-fold in order to become sufficiently visible for convincing in the short term every single consumer to buy a compact fluorescent lamp instead.

But the whole point is that you shouldn’t convince every single consumer to buy a CFL instead, since it is an inferior quality product, hated by many and containing mercury on top of it. Instead, you could convince enough people to turn down indoor heat or cooling one degree and save much more. You could reward utilities for handing out free dimmers, sensors and timers. Or you could regulate and tax junk food, which uses astronomical amounts of electricity in production, distribution and storage, and causes costly and disabling health problems on top of it.

Still the main point is that efficient lighting as provided for in the regulation is a way to save energy, to limit CO 2 emissions and to help consumers save money without loss of functionality.

As Peter Thornes keeps pointing out, it is not up to the Commission to save people money. This is just the usual sales propaganda from Market Transformation Programs rehashed to make it sound like a better idea than it is. For comparison, just think of the amount of money the average household would save if there was no junk food to buy in the shop! Or if alcohol and tobacco were banned. But the EC doesn’t really care about people’s private economy, does it?

And I still don’t see an explanation why a tax or VAT won’t work.

I.6. Alleged intrusion of Brussels into citizens’ private lives

How come the bureaucrats of the European Commission are suddenly taking a decision that affects so much the life of every European citizen?

By adopting a regulation aiming to phase out the less energy efficient lamps, the Commission implemented the specific mandate from the European Parliament and the Council of Member States as originally laid down in the Ecodesign Directive (2005/32/EC, see point II.3 of this FAQ). In its Article 16, the Directive specifically requested the Commission to introduce implementing measures on lighting in the domestic sector through this procedure.

The importance of this measure was underlined by the Spring European Council of 2007, which invited the Commission to “rapidly submit proposals to enable increased energy efficiency requirements (…) on conventional incandescent lamps and other forms of lighting in private households by 2009″ and by the European Parliament in its resolution of 31 January 2008 on the Action Plan for Energy Efficiency, where the European Parliament stressed ” the importance of the Commission’s keeping to the proposed timetable for the withdrawal of the most inefficient light bulbs from the market”. Again, in October 2008, the Council of Energy Ministers invited the Commission to ” submit in 2008 a draft Regulation that will launch a gradual process of phasing out until conventional incandescent lamps and all the worst-performing lights are banned.”

In parallel to these mandates, the Commission’s services developed a draft regulation on non-directional household lamps. The procedure started already in December 2006 through a preparatory study. After a thorough technical-environmental-economic analysis of the available household lamps and their improvement potential, which was carried out openly with the involvement of stakeholders, a working document based on these recommendations was discussed with Member States and stakeholders (including a wide range of NGOs and industry) in the Ecodesign Consultation Forum in March 2008.

Building on the opinions expressed in the Forum, and on a parallel impact assessment, the Commission’s services prepared the text of the draft regulation, which was fully endorsed in the Regulatory Committee on 8 December 2008, without opposition from any of the Member States.
The Environment Committee of the European Parliament discussed the measure on 17 February 2009 and decided not to object to it. Finally, the European Commission adopted the Regulation on 18 March 2009.

This exhaustive preparatory process has ensured that the interests of European citizens were well represented during the development of the regulation.

Hardly. Few of those directly affected were even told of this impending decision before it was too late, and not exactly informed on how to protest. And the discussion/vote was rushed through several weeks before the three month objection time was up.

Peter Thornes describes the whole charade from beginning to end here: http://www.ceolas.net./#li1ax

I.8. The quantity of savings compared to other sectors and countries

How do the estimated savings compare to the total electricity consumption the EU? Are they not insignificant, considering that household lighting itself is only a small share of the total consumption? Is it not superfluous to adopt measures that bring so little improvement compared to the whole? Other sectors and other countries could make more important savings. Why bother with light bulbs?

When comparing the estimated saving potential of the regulation (39 billion kilowatthours per year by 2020) to the electricity consumption of the EU, it may seem insignificant (1,4 % of the total final electricity consumption of the 27 Member States in 2006, which was 2826 billion kilowatthours).

Let’s see how the “1,4%” was arrived at:

Some figures for EU-27 in 2006:

Final energy consumption (all fuels, all sectors): 1177 Mtoe (megatons of oil equivalent)

Final electricity consumption (all sectors): 2826 billion kWh or 243 Mtoe

Final energy consumption of households (all fuels): 304.9 Mtoe

Final electricity consumption of households: 807 billion kWh or 69.4 Mtoe

Electricity consumption of household lighting: 105.89 billion kWh or 9.1 Mtoe = 13% of household electricity consumption, 3% of total household energy consumption, 1.4 % of total electricity consumption (all sectors)

Well, I’m very glad to find a previously unseen effort to separate sectors and not confuse electricity and total energy consumption (could it perhaps be inspired by my energy statistics posts)? Seems we arrived at fairly similar figures anyhow (= lighting around 3% of household energy use). Except on that last one. Unless my calculator is playing tricks on me, I get 0.77%, not 1.4%.

However, the total electricity consumption of the EU includes the consumption of all sectors, namely industry, transport, agriculture etc., not just households. It is clear that in order to fight climate change effectively, all sectors need to contribute. The regulation on non-directional household lamps affects lamp types that are primarily used in households (although to some extent also in non-household applications such as restaurants, hotels, shops etc.). Therefore it is fair to compare the estimated savings to the electricity consumption of the household sector in the EU, which was 807 billion kWh in 2006, of which 5% will be saved.

Here we go again using the old electricity confusion stunt to muddle the waters and make savings sound more than they truly are. 5% = 1.14% of total household energy consumption. That is, if the phase-out will truly save this much (which is won’t, see below).

The estimates above are based on the assumption that households will be using a mixture of improved incandescent bulbs with halogen technology and compact fluorescent lamps. However, switching to the exclusive use of compact fluorescent lamps and LEDs makes economic sense for households, who would save much more energy and money.

We have heard this argument a million times. It still does not address the quality issues with CFLs and LEDs. If the lamps had good enough light quality and fit everywhere, people would buy them without force, especially now that price is going down and relative quality (compared to earlier models) up. No one wants to waste energy. But some of us do care about being able to see well and have a warm relaxing lighting environment in our own homes and do not find even the best CFLs or LEDs fulfilling those requirements.

If all households switched to the exclusive use of compact fluorescent lamps and LEDs, at the EU level we would be saving 86 billion kilowatthours by 2020, which is 11% of the electricity consumption of households.

If lighting is estimated (with much encertainty) at under 13% of household electricity (I assume this is your source for that number: Residential Lighting Consumption and Saving Potential in the Enlarged EU) and CFLs save (optimistically) 66-75% of those almost 13%, how does that make 11%? 66-77% of 13 is 8.58-9.75%.

But that would be assuming a) that the 13% of of electricity use is an accurate estimation; b) that those lamps are all incandescent (which they are not, see below); c) that all CFLs work as well as claimed (consumer tests show many don’t, or else we wouldn’t need new quality labels); d) that they don’t have poor power factor (which most standard CFLs do), e) that there was no heat replacement effect in cooler regions (which there is, according to studies), f) that people wanted to buy them despite the quality issues (many don’t or they wouldn’t be hoarding incandescents), and g) that it was even possible to replace all lamps with LEDs or CFLs (which is not the case, even according to your own consultants):

VITO: “…some customers have a few light points left where they prefer to keep the GLS due to barriers for CFLi as explained in chapter 3 (e.g. requirements to color rendering, sparkling effect etc.) or because of the lamp has little usage such as in cellars, staircases or storage rooms and where full lighting is also needed immediately.”

Therefore the fantasy of replacing all home lamps with CFLs or LEDs remains a fantasy – the If-game. Let’s stick to reality, please.

The electricity consumption of household lighting is a minor part (3%) of the total energy consumption of a household (heating and water heating included).

Now we’re getting back to the proper perspective!

However, it should also be underlined that the regulation on non-directional household lamps is just one of a series of 30 or more Commission regulations (already adopted or being prepared for adoption in the near future) concerning the energy efficiency of different product groups such as televisions, heating boilers, water heaters, electric motors etc. These regulations all contribute to a combined impact that will make the real difference in terms of our objectives to reduce energy use and combat climate change.

But isn’t it true that light bulb regulation was sold to voting politicians as The Big Thing – that One Green Measure that was going to get us massively closer to the 2020 goal? Could it have been my pointing out what a drop in the energy ocean home lighting actually is in my energy statistics post, that has prompted this unconvincing retort?

And it’s not exactly a good defense of the first unpopular regulation, to state that there will be more unpopular regulations added to get an effect. I assume Heat Replacement Effect are not calculated for the other products either?

It also puzzles some of us how EU on the one hand takes the liberty of actually banning a non-harmful product, totally in opposition with the free market guideline, and strongly promoting a competing product which may harm both health and the environment and is already doing much damage to both in China*, while at the same time objecting to member state governments recommending people to buy locally produced food in order to minimise emissions from transport.** Food transport is a huge polluter and energy consumer and the less of it the better for the planet, no?

* “‘Green’ lightbulbs poison workers”
** “Swedish food guidelines meet protests from the EU” (unfortunately, this article is now removed).

I.9. Market share of different bulb types

How many conventional incandescent bulbs are in use at present in the EU, compared to energy saving bulbs?

In 2006, there were 5.1 billion lamps installed in EU households. Of these, 4.2 billion lamps were non-directional lamps, the remaining 0.9 billion reflector lamps.

Having lamps installed is not the same thing as having lamps in use. If calculations on lighting part of household energy use are based on number of lamps installed, this could make lighting appear to use a much larger part of home electricity than is actually the case. This also omits counting dimmers and sensors and how many houshold’s have learned to turn the lights off when leaving the room in order to save electricity. The EU lighting consumption study appears to confirm this:

EU lighting study: “It is not easy to compile accurate and comprehensive data on the total end-use consumption of individual equipment and appliances, as these are not usually separately metered.”

“”The first important point is that lighting data is very scarce, as is most of the different electricity enduse data for the residential sector. While it is easier to calculate the national consumption of large appliances such as refrigerators and washing machines is (equipment stock, user habit, and other influencing factors are well known), with regard to lighting data about the power installed, the number of lamps, the burning hours is often missing.”

And without the burning hours, you’re left guessing – and easily overestimating.

EU FAQ: The total stock of lamps affected by this regulation (all sectors including household, tertiary etc.) was 3.9 billion lamps in 2007. 1 billion lamps (25% of the total) were compact fluorescent lamps, and 2.1 billion were incandescent bulbs.

Source: Preparatory Study for Eco-design Requirements of EuPs – Domestic lighting, Chapter 2 available at www.eup4light.net

Always trying to make it sound as much as possible while still making things less than clear. This is what the study actually says:

VITO: Based on surveys of 500 consumers in 11 countries, the EU-27 average share per household 2007 was estimated at:
• 54% of the lamps incandescent (and decreaseing)
• 18% of the lamps low-voltage halogen (and increasing)
• 5% of the lamps mains-voltage halogen (and increaseing)
• 8% of the lamps linear flourescent
• 15% of the lamps CFL with integrated ballasts

It also indicates that incandescent lamps were expected to keep decreasing dramatically, even in the “business-as-usual” scenario (= without a ban)!!

Now, 54% 2007 means probably less than 50% today. That means 50% of those alleged but uncertain almost 13% = 6.5%. And then 66-75% of those = 4.29-4.87% of electricity, assuming a) – g) above, which again is contrary to known and provable facts, so more likely around 50%, generously speaking. Now we are down to 3.25% of household electricity consumption. Which can easily be saved by other means.

I.11. Role of the lamp industry

Did the Commission take this decision under the influence and in the interest of lamp companies?

The European Commission did not decide on its own to phase out conventional incandescent bulbs, it is done in agreement with the European Parliament and with the Council of Member States. Regulation 244/2009 was developed by the Commission on a mandate from the Ecodesign Directive (2005/32/EC) of the European Parliament and of the Council of Ministers of the Member States. The request to phase out conventional incandescent bulbs was made by the European Council in 2007 and further reinforced by the European Parliament and by the Council of Energy Ministers in 2008. The Regulation itself was prepared in an open process lasting two years with the formal involvement of stakeholders such as consumer and environmental NGOs. European industry was also consulted, they claimed initially that the provisions of the planned measure would be much too ambitious in terms of timing and requirements. However, the Commission and the Member States decided to maintain the level of ambition, with the support of the other stakeholders. In the framework of their right of scrutiny, both the Council of Ministers and the Parliament decided not to object to the draft Regulation before it was adopted by the Commission in March 2009.

That manufacturers needed longer to adjust their production once the goal was within reach does not mean that the idea of getting rid of their most unprofitable but popular lamp once and for all, didn’t originate within the industry. The global anti-lightbulb campaign, via Market Transformation Programmes, has been one of the most well-coordinated, persistent and far-reaching propaganda acts in history.

That the Commission and most EMPs have swalloed all the usual PR lines (which all you need is a manufacturer catalogue and a calculator too see are exaggerated, and which I believe was also communicated by PLDA before the EMP debate and final vote) does not inspire trust in our leader’s judgement.

Let me just emphasise that I am not against energy saving and making more efficient products. But it is not acceptable to be forced to use a lower quality product for something as important as lighting.

The Commission now keeps repeating that Halogen Energy Savers and LEDs are also available, but these products are not easy to find and were not even included in the preparatory study; all calculations were based on the naked tube CFL. This is clearly the lamp which the Commission and industry both hope we will all use in most of our lamps, despite its looong list of problems, including the mercury content. I find this more than a little strange.