Związek Producentów Sprzętu Oświetleniowego Pol-lighting
Pol-lighting
Związek Producentów Sprzętu Oświetleniowego „Pol-lighting” jest ogólnopolską organizacją producentów branży oświetleniowej, działającą w oparciu o ustawę o organizacjach pracodawców z dnia 23 maja 1991r., zrzeszającą wiodących producentów źródeł światła i profesjonalnego sprzętu oświetleniowego.
ID: 545847327078-51
Lobbying Activity
Response to Review of ecodesign requirements for lighting products
8 Nov 2018
European Commission proposes important changes compared to the current legislation. There are several good initiatives we support. But there are also propositions, which implies some serious and negative consequences for consumers, end-users and European lighting industry.
We support the proposals regarding Circular Economy written in Article 4 - the proposed rules provide clear requirements for manufacturers and for consumer choice.
We are in favour of increased enforcement of the eco-design rules and therefore proposes shorter and cheaper testing methods.
But we have to express our serious concern about the proposed premature phase-out of T8 fluorescent lamps as it is written in EC proposal for revised eco-design requirements on lighting. We cannot support the proposed phase-out of T8 fluorescent lamps in 2021 for reasons summarised in the points below.
1. Lack of economic justification: replacement costs for society
The forceful transformation towards non-T8 fluorescent lighting technologies in 2021 will cost the European society approximately € 167 billion in the period 2019-2021. This translates into an unreasonably large burden for countries in CEE like Poland, where more than 80 % of the indoor lighting in public and government-owned buildings consists of T8 fluorescent lamps.
Eighteen industries issued a common position on the premature phase-out of lighting technologies, highlighting the unreasonable replacement costs and lack of alternatives in case T8 fluorescent lamps will be banned in 2021. It clearly states that end-users need time to plan changeovers well in advance, taking into account budgeting, maintenance, and replacement cycles. A premature ban, on the other hand, carries the risk that end-users will start stockpiling the old technology, which will neutralise the desired energy savings.
2. Negative environmental impacts: unnecessary waste streams
the generation of the waste streams that will be created by a premature phase-out of T8 fluorescent lamps. It is estimated that a ban will lead to an additional waste stream of 8 million tons in 2019-2022. This is caused by a decreased availability of T8 fluorescent lamps on the market, requiring the renovation of ceilings and investments in new (LED-compatible) fixtures to avoid inconsistent lighting.
3. Substitution not available for all applications
Many available LED retrofits do not fulfil the same working standards as T8 fluorescent lamps, which further negatively affects productivity, knowledge acquisition and wellbeing. Only additional time for the LED retrofitting market to mature can tackle this issue, as a premature phase-out will only force end-users to opt for the (cheaper) noncompliant products.
4. Not transparent energy savings by simple retrofitting
5. Negative implication for EU Lighting Industry
In our opinion, the T8 phase-out is inevitable but the further transformation of conventional lighting market (which today is energy efficient in the sense of the current eco-design legislation) has to be done in evolutionary way.
We propose to ensure the placement on the market of T8 fluorescent lamp units until 2025 or at least the next revision of the legislation for replacement purposes, as supported by the Czech Republic, Germany and Poland in written form and other Member States during the Consultation Forum of 7 December 2017.
ZPSO “Pol-lighting” fully supports the objectives of eco-design legislation to achieve substantial energy savings. However, this should not exclude balanced measures to achieve those objectives, so that consumers, end-users and industry will have adequate opportunity to adapt.
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Read full responseResponse to Review of energy labelling requirements for lighting products
6 Nov 2018
Warsaw, 6 th November 2018
EPREL
Comments
Energy Labelling
We support the proposal to limit the energy label to light sources only. In our opinion discontinuation of the label for luminaires is right, since it has no real benefit for consumers.
We hereby declare on behalf of Pol-lighting the following:
Scope and timeline of EPREL
1. Data base EPREL - industry's arguments against creating this database in such a short time:
a) Manufacturers' difficulties to estimate costs related to entering data, updating and IT support of the database.
b) Unrealistic date of implementation of the database;
c) Lack of information about the infrastructure to create this type of database.
d) Imprecise material scope of the EPREL database.
e) Excessively complex databases may result in delay in the introduction of new lighting products.
Comments:
1. Doubts about the reliability of information contained in the EPREL database. Dishonest suppliers may place false information about the products being introduced. The database cannot replace reliable market surveillance.
2. The process of creating such databases lasts at least a few years. Let's also remember about completing and maintaining the database, which is time-consuming and expensive.
3. The EPREL database is aimed at consumers. According to the proposals, the information contained therein is, in the opinion of specialists in lighting products, too complicated and incomprehensible for
an ordinary consumer. Therefore, the material scope of information in the EPREL database should be
a consensus developed together with the lighting industry.
4. The database is aimed at consumers, i.e. should only include light sources intended for direct sale to consumer.
Formatting
Regarding formatting we are in favor to maintain as it is in Reg.874/2012.
What means the possibilities to print:
• A horizontal label
• A greyscale label
• A label in smaller format
Emergency lighting
Emergency lighting should be excluded from the scope of the ELR
Market Surveillance
The creation of the EPREL database will not result in the products being put on the market suddenly being of high quality in accordance with the standards, Regulations.
The own declaration in the database that the product complies with the legal requirements applicable in the EU is not a confirmation that this is the case in reality. There is a risk that the suppliers, including the importers will enter in the database false information about the product, quoted UKE Raport:
https://archiwum.uke.gov.pl/files/?id_plik=22199
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