Lighting EcoDesign Update - Summer 2021

Last year, I wrote that we’d worked with the EU to tidy up the final details of their Ecodesign regulation, correcting the little anomalies that had crept in and could have threatened the availability of, in particular, high-output white LED-based lighting fixtures, things like followspots or stadium-scale moving lights. Those corrections were voted on and accepted as part of the ‘Omnibus amendments’ to the Ecodesign regulations in November 2020. Job done...

Except of course that those regulations don’t come into effect until later this year, September 2021. Which means these rules weren’t in effect last Christmas at the point of that little thing called Brexit - so they didn’t automatically become part of UK law as part of that process. Job not quite done.


A few days after the Omnibus amendments were accepted last November, an email arrived from the UK Government’s Department of Business, Energy and Industrial Strategy (BEIS), which oversees this regulation in the UK. They were starting a consultation on the new draft Ecodesign and Energy Labelling Regulations (Light Sources) 2021 for the UK...

In effect, as a starting point, they had copied and pasted the EU regulation and changed the title. Unfortunately in an unfortunate fluke of timing, they’d copied and pasted the pre-Omnibus, so without any of the corrections we’d worked so hard to achieve. Deep sigh...

BEIS were running a public consultation on this, and while we completed that alongside PLASA and the other members of the Ecodesign coalition, we also got in touch with BEIS directly. Interestingly this was now largely a different team of people to those we’ve dealt with there over the last few years, and so it was almost like starting all over again in terms of explaining what we do and our issues, but the new team seemed receptive and interested. The result is that their text has been updated to the Omnibus edition, and so UK law (in England, Scotland and Wales at least) and EU law will continue to match - for now.

How long that continues to be the case is anyone’s guess. In early discussions it felt like the UK team thought the EU regulations were overcomplicated, full of strange exceptions and workarounds. The hint was that BEIS would like to throw that all away and get back to a very simple lumens-per-watt efficiency requirement. Of course that’s what the EU also wanted to do; we fought that for very good reason, and other industries that use light fought their cases for their own very good reasons, which is why the regulation ended up so complicated. I suspect the issue is really that it is trying to deal with too many disparate uses of light, from domestic lighting to tanning to industrial processes. Through the responses to their public consultation and a couple of on-line panels they held which we took part in, I think BEIS have understood that and are now re-considering their approach.


Meanwhile in Europe, the EU is starting to plan their next set of revisions to Ecodesign. It feels like there is a realisation that further big reductions to energy use will be hard to achieve, and so attention is turning to improving the working life of products, their repairability and, ultimately, their recyclability. Some of these aspirations were in drafts of the current Ecodesign regulations but were ultimately edited out. Bringing them back would be no bad thing.

The danger, of course, is if the EU does one thing and the UK something entirely different (in Ecodesign, and in other regulations such as ROHS which the EU is currently updating and which we are also monitoring), which would be a challenge particularly for manufacturers selling in to both markets. That’s really what we’re keeping an eye on now, all of the organisations who’ve collaborated in this process up to now, co-ordinated through Pearle in Brussels, having agreed that we’ll keep working together and will keep presenting our case and promoting our interests jointly to the EU and to the UK so the message remains consistent.


As I said last year, what all this means for end users is that manufacturers will be allowed to keep on selling pretty much all of the products you know and love, fixtures and bulbs - with the key exception of tungsten M16 lamps which were always really a key target for Ecodesign. But as I also said last year, whether they actually want to keep on selling or even making those products is a whole other question, and there are a whole raft of tungsten bulbs that are now out of production. If you relied on those products for your rig, how you dealt with that was always going to be a challenge, all the more so after a year of no income. But ignoring the problem and doing nothing won’t change anything, and as before the ALD continues to be here if you need advice on how you could evolve your lighting system without sacrificing the quality of light that is so important to us all.


The EU Moving Forward


The UK Moving Forward


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