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International Association of Lighting Designers Europe

IALD Europe

The Vision of the IALD is to create a better world through leadership and excellence in lighting design; to cultivate the universal acknowledgement and appreciation of the Power of Light in human life.

Lobbying Activity

Response to RoHS deleting exemptions for mercury in double-capped linear fluorescent lamps for general lighting purposes

15 Jul 2021

While we agree with the intention to remove Mercury from lighting products completely, the current proposal and suggested timelines offer very significant challenges. While it is some time since we last specified fluorescent tubes on a project, in the case of my practice over 5 years, these, particularly T5 HE were still at that time the most energy efficient and cost effective light source for many projects. Our clients relied on our best advice at that time in selecting these products. On the current proposals these installations will become obsolete and in some cases require wholesale replacement or, at the least, loss of control capabilities provided for energy savings including presence control and daylight harvesting. While there are a number of LED direct replacement lamps available these are incompatible with dimming control systems designed for T5 and T8 fluorescent lamps. It seems distinctly unfair on building owners and users who have, in the past decade installed lighting systems specifically designed for energy efficiency to have this investment negated so quickly. The other significant result of the current proposal is absolutely contradictory to the principles of Circular Economy that are being introduced to energy efficiency regulation including EcoDesign as it will result in a large quantity of fluorescent light fittings and control systems being removed and scrapped or recycled well before the end of their normal working lives. Finally, echoing the comments of Lighting Europe and others, the timings of these actions should be synchronized with the cycle of changes to the lighting market through EcoDesign Regulation. Currently everyone in the lighting community is in the process of adapting to the new EcoDesign regulations active in September this year. These already have a forward action in 2023 that removes many of the affected general lighting lamps from the market. It makes regulatory and economic sense to extend the exception on lamps affected by EcoDesign until at least 2023. For those lamps not so affected a minimum 5 year extension should be provided to allow existing installations to reach a reasonable payback period before requiring replacement. Kevan Shaw for the International association of Lighting designers 15 July 2021
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Response to Sustainable Products Initiative

5 Oct 2020

See file attached
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