Updated Dec 2012
Let’s look at the crucial parts of the European Union’s amended (Oct 2009) Ecodesign Directive:
5. Implementing measures shall meet all the following criteria:
Please notice the word “all”.
(a) there shall be no significant negative impact on the functionality of the product, from the perspective of the user;
• With CFLs, the user gets poorer quality light with suboptimal colour rendering (CRI 81-83 of 100), sensitivity to heat, cold, moisture and frequent switching (not recommended for bathrooms and shortly visited spaces); that may not fit well in many existing luminaires; is often incompatible with dimmers, (will fry existing electronics); may cause disturbances on the grid and use more power than marked watts; has recycling difficulties (being hazardous waste they must be taken to special recycling facilities, often reachable only by car, instead often contaminating other recycling materials); and risk of mercury contamination of one’s home if accidentally broken.
• With LEDs, the consumer gets a poorer quality, dimmer light with often strange light colour, dimmability problems, suboptimal colour rendering; extremely high purchase price and poor electromagnetic compatibility (may disturb the power grid and other electronic devices).
• With clear class C Halogen Energy Savers, you get good quality light but more glaring and can get very hot. Frosted would be ok but they were banned 2009. Clear class C halogen lamps will be banned 2016.
• With clear class B Halogen Energy Savers with integrated transformer; glare, higher EMFs, very high price, and not available on the market at all! The only European manufacturer who made these lamps for a few years, Philips, replied when asked a direct question, that that they have no plans on re-introducing this halogen lamp on the market, and that all R&D will go towards developing [the more profitable] LEDs.
–> Thus, this condition is not fulfilled.
(b) health, safety and the environment shall not be adversely affected;
• CFLs can not be considered anywhere near safe for health or environment as long as they are breakable and contain highly toxic mercury vapour. Increased mercury mining in China due to rising demands from the West is causing an environmental disaster in Asia! CFLs may also emit other carcinogenic chemicals and UV radiation (through cracks in the phosphor layer in the inside of the tube).
• LEDs can also flicker, contain toxic chemicals, emit potentially harmful amounts of blue light and cause health problems for a number of patient groups, as well as disrupt circadian rhythms.
As there are also many patient groups, an estimated 250 000 light sensitive people in EU which SCENIHR thinks will be adversely affected, and anecdotal evidence for even more patient groups reporting everything from subjective discomfort or serious illness in FL/CLF and LED light. Others have estimated that 2 million will be affected in the UK alone.
–> Thus, this condition is not fulfilled.
(c) there shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle cost of the product;
• The reason standard CFLs are now more affordable, besides competition from poor quality no brand bulbs, is that they are often subsidised by tax money. Your tax money. And you may also be paying an extra nominal fee on your electricity bill to compensate for the poorer power factor of most CFLs, LEDs and other home electronics. In both cases: whether you’re actually using them or not.
• Dimmable CFLs and LEDs are still prohibitively expensive to buy, even if they allegedly last longer. And most of the replacements don’t save as much as claimed, give as much light as the lamp they replaced, or last as long as promised. Burned-out CFLs often have to be delivered by car to special collection places, or to recycling stations for hazardous waste.
• Recovery of the higher purchase price is dependent on the product lasting as long as advertised, something which CFLs continue to fail even under optimal lab testing conditions, and even more so in real life conditions where they easily get overheated or get switched on-and-off more frequently than recommended etc. The promised life of LEDs still remains to be proven. As CFLs and LEDs become dimmer over time and some also change colour, they may neeed to be replaced even before they burn out prematurely.
• Savings are also 50-60% less in North Europe due to the scientifically established Heat Replacement Effect.
• The whole life cycle cost of the product typically never includes the mining of the mercury, phosphors and rare minerals in Asia, and all the cost to health & environment for the workers there. Nor for the shipping of the many electronic and chemical parts over Asia for assembly in a specific factory; shipping by polluting oil tankers from Asia to Europe; transport to recycling facility for toxic waste after the lamp has burned out; and then for the complicated recycling process to recover the mercury and cleaning the glass; and finally for depositing the mercury and other toxins as they cannot be exported from EU according to the RoHS Directive.
• If a CFL breaks in your home, you should first of all already have bought an expensive mercury spillage kit for safe clean-up. Then you may have to replace all carpets, textiles and other contaminated things in that room. If your children inhale the noxious mercury vapour, they may become sick and develop learning disabilities for life. What is the cost of all this?
–> Thus, this condition is not fulfilled.
(d) there shall be no significant negative impact on industry’s competitiveness;
(e) in principle, the setting of an ecodesign requirement shall not have the consequence of imposing proprietary technology on manufacturers; and
(f) no excessive administrative burden shall be imposed on manufacturers.
I’ll leave that part for manufacturers to comment, on the remote chance that they find anything to complain about, as the ban has been a direct result of their lobbying. But they have had to change the lamp labels to include much more information than earlier. And I believe leading lamp manufacturers hold most of the patents for creating decent LEDs.
= As A, B, C are clearly not fulfilled, the incandescent phase-out is invalid and should be revoked immediately.
• Furthermore, naked tube & spiral CFLs for private use should be banned effective immediately, as they are a hazard to health and environment both! This is very urgent and imperative!
• LEDs should also be restricted to professional use only, due to the blue light hazard – which is greatest for children and certain patient groups – and/or only warm-white LEDs allowed on the market.
• A special ban on cool white/light blue lamps for vehicle headlamps is urgently needed for safety reasons, as glaring blue-white light is a very real danger to traffic and vision both.
• The old ineffective Mercury Vapour street lights should be banned according to schedule as there are more effective replacements with better colour rendition, such as ceramic metal halide.
• All other gas discharge lamps should be permitted on the market in order to offer lighting designers and engineers a full range of options for various situations when lighting public spaces. Different environments call for different lighting solutions, optimised for that particular situation. Sometimes more quantity than quality is needed (e.g. in parks and attractive tourist areas), sometimes quantity and long life is the highest priority (e.g. for illuminating highways). Each type of lighting has its unique qualities and one lighting technology is NOT replaceable by another without getting completely different light qualities. Lighting designers know this and are well educated to choose the most optimal lighting technology for each situation.
Light is a bio-nutrient just like food, air and water, and good light quality should be a basic human right. The quality, colour, colour rendition, direction and quantity can have a very profound effect on how a space is perceived, as well as direct biological effects on the endocrine system, vision, mood and performance on normal healthy people. Lighting is also one of the most potent mood enhancers at the disposal of an interior designer, architect or lighting designer.
Restricting choices for both professionals and for the general population is just wrong, unless a product is found harmful – such as the CFL and some LEDs.
Banning fire-based incandescent light in order to force everyone to use chemical-technical light is the equivalent of banning water in order to force everyone, including diabetics, to drink only Coca-cola when they are thirsty. That’s how big the quality difference is. Truly. Just check any manufacturer’s online catalogue. Even the best CFLs and LEDs for the consumer market only have 80% colour rendition (CRI) whereas incandescent and halogen lamps have 100%, just like sunlight.
Anyone can see this for themselves by taking a dark room and lighting it first with CFLs or LEDs (especially one’s that have been used for a few years) and then light that same room with only incandescent or halogen light and you will see that in the former you will strain your eyes to see anything through the dim, gloomy, greyish fog. With incandescent/halogen light you will see and feel like letting in the sun on a cloudy November day; all colours will come alive and look more brilliant, and people will no longer have a sickly pallor.