Incandescents: The Real Green Bulbs Also in Canada

As the Canadian comment process finishes, as an American incandescent ban largely finishes on January 1, and as the EU review process also seems to have concluded in its first phase, some concluding remarks to the last series of posts seems apt.

The ban, not just on light bulbs but on much else in society, is largely driven by 2 aspects, supposed savings and product progress. Both have been well covered, but product progress deserves extra mention in an overall conclusion.

Product progress?
Product progress arises from increased, not decreased, market competition.
Energy saving progress in particular has been continuous throughout history.
Fluorescents and LEDs? On the market, without bans.
Solid state transistors replacing incandescent tubes? On the market, without bans.

Light bulb manufacturers could themselves simply stop making the "terrible incandescents".
That's what the very same companies normally do in the name of progress, they already stopped making cassettes, video cartridges, 8-track systems and much else.
Certainly they got - and get - lots of taxpayer subsidy goodies to make alternative bulbs while still slapping their own patents on them for yet more profit, and certainly politicians feel obliged to further help out their subsidised buddies sell more bulbs (as the Canadian proposal says, in so many words, in justifying bans because of committed investments).

The supposed problem is therefore that idiot citizens choose not to replace all their existing bulbs with the pushed alternatives, disregarding that most citizens - as the ban brigade keep saying - indeed have bought some for the advantages that they of course also have.

Of course, politicians don't want to declare their voting citizens to be idiots in what they choose to buy. Not openly, anyway. So the roundabout talk is that
"Regulations force faster development of better new products":
"Better" always being energy saving in usage with disregard to all else, including overall savings.
Obviously by necessity this brings new alternatives, but it is development that aims to fill the gap of popular incandescents - look at all the LED incandescent bulb clones. Hardly true or exciting progress.
As said, intrinsic advantages are of incandescents as bulbs, fluorescents as tubes, and LEDs as sheets, and was the original development of the latter 2 products, before all the push to compromise them as bulbs (yes, still with advantages of their own technology, but hardly developed as such now in bulb format, eg the flexible color temperatures of RGB LEDs rather than White LED bulbs).

A further issue is that regulation cut off standards don't just ban what exists. It bans all that could have existed, and never will, despite possible advantages beyond consumption of energy in usage. This, as with all else, is the case not just with light bulbs in the worldwide totalitarian definition of progress.


Everyone can have different legitimate views of the necessity of targeting products to save energy.
But what is then surprising is the complete lack of analysis of alternative policies.
Politicans? Media? Total silence.

Alternative information, taxation, market policies as thoroughly covered in the last post.
As the most fervent political, media and lobby grouped ban supporters tend to have a green or left-wing persuasion, the avoidance of all consideration of taxation is particularly puzzling. Even a mid-size 35 million country like Canada has well over 100 million in relevant sales, while in pre-ban USA and EU it runs into 2 billion sales in each case, of a cheap easily taxable product with high turnover, that could help all the " public spend" measures these people want.
In the USA, the California government is bankrupt - yet, like Canadian British Columbia, they ban every product in sight, instead of taxing it, and could of course announce it as subsidising cheaper alternatives re any "we hate tax" issue.
The point is not that tax is good. The point is that it is arguably better than bans for those who favor bans, while the market stimulation alternative is still better on the argumentation given, if light bulb targeting is (dubiously) deemed necessary.



So, to turn it all around.
Green is a color with many hues!

The case for looking at incandescents as the true environmentally friendly bulbs has been made earlier here.

That can be expanded on, and also put into a Canadian context, given the last series of posts here. The following is based on section 10 of the reply to the Canadian proposal for January 1 regulations on light bulbs, but as seen, it is generally applicable everywhere...

M'Lords and Ladies, the case for the humble simple incandescent light bulb:


Efficient?
Certainly efficient, in making bright light using few components


Earth Saving?
Certainly sparing the earth much mining for minerals


Long Lasting?
Certainly they can last long, at least to 20,000 hours at low price, as shown by mentioned small manufacturers, when major manufacturers don't control the markets.


Sustainable?
Certainly sustainable, in being easily locally made generic patent-free bulbs,
without much transport of parts or product, and without needing recycling.


Incandescents don't burn coal and they don't give out CO2 or other emissions.
Power plants might - and might not.
If there is a Problem - deal with the Problem.

Electrical products are only indirectly coupled to any energy source use, and in turn, the main evening-night time use of incandescent bulbs really only consume small amounts of off-peak surplus capacity electricity anyway, as seen.

Power plant emissions are decreasing on present policies, both from alternative source use and in directly being reduced and treated in various ways. Small overall off-peak bulb use and coal power plant night cycle operational factors reduces if not eliminates supposed bulb ban emission savings, and in a country like Canada of 86% emission-free electricity a ban even increases emissions on the heat replacement effect.



Incandescent light bulbs:
A pointless very visual feel-good target for an agenda driven ban seeking to ensure that the world loses the simplest cheapest product it ever had to produce light from electricity,
an aesthetically pleasing versatile invention, whose doom would arise not from being unpopular, but from being popular, through the stupidity that passes for global governance.




How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

Canada and Nordic Countries: Incandescent Light Bulb Usage Advantages

... it's about a lot more than the heat of incandescent bulbs!

Update info: Campaign against the ban by Ontario MP Cheryl Gallant:
stop the ban page (with petition), facebook page

See the last post.
It focuses on policy aspects of the Canada Government proposal to switch to USA standards.
A main claim is that Halogens "similar to traditional bulbs" will still be allowed, but they will be banned under US law as referenced, and the Government proposal itself speaks of further standard restrictions being facilitated.
While section 3 will remain there, having already linked to it in correspondence etc, it and some other sections have a general informative aspect so may be further highlighted separately.

To recap:
This is part of a reply to the Canadian Natural Resources Government Ministry, Office of Energy Efficiency, concerning the Canada Gazette Vol. 147, No. 40 — October 5, 2013 published proposal on Light Bulb Regulations to be effective as from Jan 1 2014,
and the invitation to comment by December 19th.


Below is seen section 3 of the following:

1. Why Alignment to USA will also ban Halogens
2. What is good for Canadian Industry, Jobs and Consumers?
3. How Incandescents have particular Advantages for Canadians
4. Simple Incandescent Advantages versus Halogens
5. On Energy saving for the Nation
6. On Emission saving for the Planet
7. On Money saving for the People
8. Worldwide Policy and Major Manufacturers
9. Alternative Policies targeting Light Bulbs
10.Incandescents - the Real Green Bulbs?

Full version:  As Doc    As PDF



3. How Incandescents have particular advantages for Canadians

First, a summary of general advantages of Incandescents, then particular advantages to Canadians.


General incandescent advantages

A high quality 100% CRI (color rendering index) light with a warm characteristic: Incandescent lights have a smooth broad light spectrum, which in ordinary light bulbs rises more towards the red end, giving the characteristic warm glow, increased on dimming (fluorescent and LED lights give out different types of light...LEDs also in car headlamps, bicycle lights, flashlights/torches, sees an often bluey omnidirectionally weaker but point source glare type of lighting taking over in society).

The light bulbs have for many a pleasing simple appearance, and the transparency sparkle effect makes their use in some lamps, lanterns, and chandeliers attractive.
They are versatile with dimmers and sensors, advantageous where vibration or rough use is expected, and in very hot or cold conditions when they are also quick to come on. Moreover, the heat of the light bulbs (of itself often useful) finds direct applications in space heating applications, greenhouses, hatcheries, pet keeping etc.
Converse arguments note the situational disadvantages in particular of CFLs, for example in recessed and enclosed fixtures or humid (bathroom) situations



The brightness issue

Small and standard size incandescent lights are particularly useful, since CFL or LED equivalents usually can't be made as bright, and when they can they are even more expensive than usual.

The early ban on small/standard 100 Watt bulbs is therefore particularly ironic, added to by any future absence of halogens.
Such bulbs have especially good and cheap brightness as well as heat benefit, with 100W bulbs being at the same low price as other bulbs (and yes, that is also a reason they "must" be banned quickly based on what people might otherwise want to buy, such that big "savings" can be announced instead).

Fluorescent and LED lights, often dim to start with, also dim more with age, shortening lab quoted lifespans.
Fluorescent encapsulation (with pear shaped outer envelope, recommended for close use) further reduces brightness, similarly the phosphorescent covering of LEDs to spread the point-source lighting reduces brightness in any direction.
Cheap Chinese imports, directly or for assembly and rebranding, also mean that brightness retention, lifespan and other issues remain with these lights.
Any older reader might like (or not like) to note that not only do older eyes need brighter light, but ageing also means yellowing eye lenses so that they absorb the greater blue light component of fluorescents and LEDs, making them appear still dimmer.
Je vous souhaite la retraite agréable.



Safety issues

Normally products are banned for being unsafe to use.
The irony here is that old and thereby well known bulbs in their safety are forcibly, albeit gradually, replaced by CFL and LED bulbs with several health, safety, and environmental concerns.
There is little point in going through the concerns here which can easily be found in online discussion and documentation -
especially regarding fluorescent lighting mercury and radiation concerns, which after all also influenced the 2 year regulatory delay in Canada. Those issues have of course not simply gone away, including accidental breakage of CFLs and their recycling as alternative to being dumped (and with some calls for LED recycling too, see below).
A point of irony is the light bulb heat issue.
Irony, because politicians and journalists and indeed the info sheets from the OEE (Canada Gov office of energy efficiency) love to say how incandescents "waste 90-95% of their energy as heat", never a word that CFLs also waste 70-80% and current LEDs 50-70% of their energy this way.
Irony, because while much incandescent heat is radiated externally to potential use, CFL and LED is internalized, with unpredictable fire risk, especially of CFLs (incandescent heat being more noticeable in burning lampshades and the like, to warn users).

Not only do incandescents often usefully release around 95% of their energy as heat:
Proponents conveniently "forget" to add that CFLs and LEDs really waste energy as heat, CFLs 80% and LEDs 70%.
That is because the CFL/LED heat is internalized, to give a greater, unseen, unpredictable fire risk, particularly with CFLs (incandescent heat being more noticeable, to warn users).

A brief further word on LEDs, as the touted catch-all replacement product.
Just to mention 2 aspects and 2 institutional references.
The official French health agency ANSES in a 2010 multi-disciplinary study highlighted point source glare and blue light radiation issues and various side-effects, echoed by several other studies, and unusually in a repeat call 2013 complained to the Commission that nothing was being done.
Similarly the Department of Chemical Engineering and Materials Science, University of California, USA has been involved in several multi-disciplinary and multi-institutional and international (Korea) studies concerning the toxicity and environmental effects of LEDs, including depletetion of rare earth minerals, and calling for recycling as with CFLs.



Certainly, new technology should be welcomed for its advantages.
But it does not necessitate banning the old - it seems remarkably hard for politicians to understand that manufacturers themselves can and do move on the new products, without the necessity of bans, and that there are many other ways both of reducing energy consumption in general and of enhancing energy saving product purchase in particular.

Progress is welcomed - not feared.
True progressive politics brings more choice and more advantages, a progress helped - not hindered - by allowing competition against that which already exists.

Politicians love to keep saying how "energy saving products are getting better and cheaper all the time".
Good.
Then presumably people might actually buy them - voluntarily - while still allowing niche special use of "old" varieties.
We've witnessed an incandescent to solid state switchover before - and with the same GE, Philips etc companies.
The audio version. Incandescent audio tubes to solid state (LED-like) transistors.
Now then: If that had been today, then worldwide the call would have been to ban the "energy guzzling" audio tubes.
Which in turn would have prevented rock era tube amps and other niche audio processing developments.
Politicians set energy cut-off standards thinking they just ban existing products. But they also ban what might have existed, and never will.

Ergo:
New lighting is better - why ban old lighting, no point
New lighting is not better - why ban old lighting, no point




Incandescent advantages for Canadians

(i) Canadian homes tend to be big in international comparison, with more light bulbs:

Canadian around 35 light points per home, EU average 20-25 (less in Southern Europe), USA 40-45

Thereby:
• Increased variety of conditions where different lights are useful, so a ban on any lighting type is felt more.
• More individual rooms and lamps with lights that are not often used - reducing supposed running cost savings after buying expensive "energy saving" lighting



(ii) Canadians have a higher need and usage of lighting itself:

• Increased time indoors, including at home, because the homes are bigger, better and more comfortable, related both to the cooler climate and to a greater household wealth, compared with most other countries.
• Increased time indoors, including at home or other situations where the lighting can be chosen, because of colder climate and also because the dark winter season is only partially offset by summer brightness for working Canadians outside vacation times, when some rooms will likely still need to be lit up fairly early



(iii) Canadians more often have cold conditions that can affect the lighting used:

• Incandescent lights come on quickly in the cold. While nowadays CFLs have little delay in ordinary conditions, that does not apply in cold conditions.
LEDs also are more sensitive to ambient temperatures (both hot and cold performance deterioration).
• Cool or cold conditions can combine with other usage factors unsuitable to other lighting, like incompatibility with sensor systems and/or frequent on-off switching, as with hallway and passage areas, bathrooms, outdoor porch and garage lights.
On a more curious note, replacing incandescents with other lighting has reportedly seen Canadian traffic lights being obscured by snow in wintertime, whereas beforehand the incandescent heat would keep the lights clear.



(iv) Canadians particularly benefit from the light bulb heat effect:

• The heat effect, of which more later, gives an overall reduction of energy use to maintain room temperature.
That is not just from being used more than air-conditioning cooling through the year. Even in the summer, when it is dark, it may be cold enough to turn on room heating. Besides incandescents can be changed as desired if conflicting with air conditioning - and may of course be preferred anyway for their other advantages.
• The house insulation factor: Well built Canadian houses that are well insulated, giving a greater light bulb heat benefit compared to more poorly insulated ones elsewhere, as in the UK. The heat from bulbs stays in the room, not escaping through the ceiling.
A point of irony is therefore how governments are increasing home insulation schemes to save on heating, while banning bulbs which, proportionate to small energy use of course, would thereby contribute more to such heating.



(v) Canadians are more likely to enjoy the psychologically warm effect:

Incandescents tend towards the red end of the spectrum, while unmodified fluorescents and LED lighting have more blue light, cooler in effect.
Also, when dimmed, the warm effect of incandescents increases: and people in northern countries like Canada or Nordic Europe are more likely to entertain others in their homes for say dinner parties, possibly also for cultural reasons.
Compare with warmer regions where people go out more to socialize, have no control over such lighting used, and barely use their own home lighting that they can control.



(vi) Canadians are more likely to enjoy bright light:

Having longer darker winters, and generally with less bright conditions than more tropical locations.
100W+ bright equivalent lighting is less easy to make in fluorescent or LED bulb form, is not often available for general household use, and is particularly expensive when it is (and is still not widely possible omnidirectionally with LED bulbs).
The importance is also seen from the existence of SAD, Seasonal Affective Disorder in Northern countries generally, where the lack of light during winter months plays a role as seen from the bright light phototherapy treatment that is involved.

[ Sections 4 to 10 can be seen via doc or pdf download, see top of this page]



How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

Learning from History: Audio Incandescent and Solid State

Revision, additions: December 2, November 29     Original Post: November 28

The beginning of the EU review of the 2009 light bulb regulations which sees the November 25 launch of the EU (European) Commission alteration proposals has been covered here earlier with extensive analysis.
Subsequent posts have covered industry views, mainly LightingEurope (Philips, Osram and other manufacturers).

The main recommendation here as part of the first stage 6 review by the Commission, concerning the future of halogen replacements, is to allow frosted halogen bulbs, which were not banned for any energy efficiency reason but rather to push sales of CFLs, an outdated legacy ban given that solid-state LEDs exist in both clear and frosted versions and will "be bought more and more" according to both the Commission and its energy efficiency advisers, on the basis of becoming "ever better and cheaper", which rather takes away the whole point of the ban.


Compare the close historical relationship to incandescent audio tubes/valves...
after all, who are the major light bulb manufacturers?



source  vintage ad browser

     





The tubes (structurally like incandescent bulbs) were not banned in radios and other audio equipment when "ever better and cheaper" solid-state transistors (structurally like LE diodes) came along: manufacturers - not governments - supplied energy-efficient market demand.


Today's EU Commission would have jumped on top of the "energy-guzzling" tubes.


Never mind that they have retained niche uses - and launched a rock and roll guitar amplifier age.
As with light bulbs, the Killjoy Commission would have been at the forefront of ban implementation to make sure that never happened - which just goes to show that setting usage standards does not just ban existing products - they ban what could have existed, and never will.
Relating such argument to light bulbs, see the post "What We Will Never See".




So who do the Commission talk to about all this?
"Stakeholders".
Ordinary people are never seen by the EU as stakeholders. They just have to swallow what's coming to them.
In fairness, "everyone can't be heard", but Consultation Forums that fill the room with Energy Agency Yes-Men hardly make for balanced conversation.

This is also why alternative views to the EU process have been posted here in recent days.




How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

Kevan Shaw Report: November 25 EU Consultation Forum

Regarding the EU Consultation Forum on domestic lighting November 25 meeting in Brussels
A report was posted here November 26.

Reproduced here:

Concerning the EU (European Commission) Light Bulb Review and their proposal to alter the regulations as laid out in detail previously:

Yesterday saw the previously mentioned meeting in Brussels of the Consultation Forum involving the Commission, national energy representatives and a few lighting "stakeholder" delegates.
I will expand on anything arising out of this: Suffice to say that while LightingEurope (representing Philips, Osram, GE and other major manufacturers, pre-meeting official statement of their position) and a few other lighting representatives were for the continuation of halogens without time limit, most of the energy agency type people predictably wanted to keep the 2016 ban, with some national representatives (eg Germany, Austria and Italy) wanting at least a delay, in that sense siding with the Commission 2 year delay proposal.
As this was just a consultation, decisions will take some time yet. Final decision on all aspects of the regulation review will be made by April 2014.

The most surprising aspect of the meeting was the focus on clamping down on "rough service" type industrial bulb sales to ordinary consumers - EU light bulb sales inspectors will likely be authorised to patrol the sale outlets of member nations, as already demanded by Energy Commissioner Oettinger for his native Germany. The idea therefore already has strong backing from the boss - and this time nearly all are for it, including the major manufacturers, as a lot of those bulbs are cheap Chinese imports. Thereby also "useful EU job creation" achieved. General applause.
What, the consumer? When were consumers ever important?!


#   #   #


Award winning (Lux UK Designer of the Year) Kevan Shaw of SavetheBulb.org has published a fuller analysis of the meeting and future prospects... The Latest from Europe

Extracts, my highlighting:

The Latest from Europe

Review of Ecodesign regulation 244/2009 stage 6

The Consultation meeting that took place in Brussels on 25 November revealed clearly that the EcoDesign process, particularly for lighting products is now only a political action.

In the meeting the majority of the national representatives spoke against delay or removal of the ban, not for substantial reasons of energy savings but because it might be seen as a precedent for delays or revisions for other products in the EcoDesign system.
There was also considerable support not to look at this issue in isolation but conflate it with the omnibus review of the regulation next year to save these civil servants from having to attend any more meetings where they are clearly completely out of their depth on fundamentals of the technologies being discussed.

The gloves are also off the conceit that these regulations are “Technology Neutral”.
Clear statements were made that funding would be provided for SSL but not other research.
[this was also seen in the circulated Commission proposal leading up to the meeting]

The UK representative claimed that the statements in lighting industry press clearly showed that SSL was the "only future for lighting". This obvious gullibility to marketing messages is truly scary in the context of pan European regulations that will, in effect kill off the only remaining bulk lamp manufacturing in Europe, which is tungsten halogen.

There is also seemingly no need to prove that the existing regulation has been effective in its core purpose of saving energy. The argument here is that energy use may have gone up despite the regulations but if the regulations had not been in place the increase would have been far worse!.....It was pointed out that the regulation has been very effective in bringing to the public’s attention that "something was being done" about energy use in Europe.

As for any negative impact on consumers, these are brushed under the carpet of savings on energy bills.
The unrealistic life in service expectations of extortionately priced SSL lamps, again largely statistical rather than actual, feed this argument.
Health concerns? Not the concern of this process SCENHIR deals with that.
Product safety? Again not a concern of this process. In the last year there have been 6 recalls of LED replacement lamps that I am aware of. These have been for life safety issues, touchable parts of the lamps becoming live to mains electricity. Throughout my long career in lighting I can only remember one recall of an incandescent lamp and that was because some shattered when they failed at end of a full service life.

There was some indication of the expectations of the omnibus review.
Spearheaded by Sweden and vociferously supported by CLASP the umbrella research organisation funded by the green pressure groups including WWF, Greenpeace etc, the proposal is that only A class lamps should be available in the market by 2020 if not sooner! ....Even SSL will not be able to deliver the warm colour appearance good colour rendering light that we are used to at the levels of “efficiency” demanded.
The near future looks like becoming cold and dead looking place.

Comment

Excellent if a little depressing!

The declared position of the main lighting manufacturers is as seen against the energy agency type people, but clearly
their worry of losing profit is not the same as when cheap simple incandescents were legal.
It would rather seem to be a marketing exercise for manufacturers to support the more expensive halogens, also presumably having more of an "ear to the ground" of what consumers want - compared to the civil servants and ideological fanatics as per the above. But manufacturers also know full well that they can simply point a finger at the Commission for any unpopular decision made (and in addition can then claim to have "tried on behalf of consumers to save the halogens"). Maybe that's their game all along - they know full well the position of agencies and Commission, and at the end of the day can simply count the profit - and reap all the subsidies - pertaining to LED manufacture and sales.
That leaves naive people like me thinking that manufacturers, for once, might have been concerned about people's choices without wholly regard to profit.
But, to repeat, manufacturers can and arguably should lobby for profitable decisions on behalf of their shareholders.
The problem, as always, is the extent that the Commission only listens to them, or indeed the national agency types or environmental pressure groups - which brings us back to the democratic acceptance of other views, and the various comments by other groups and individuals as highlighted here in recent days.


There is a further aspect to the review democracy, as highlighted by these type of meetings:
Not just who is allowed to attend, and not just that others are not heard (file your opinion in the waste paper bin/trash can), but of knowing who was there in the first place.

Who sits on the "Commission Ecodesign Committee", that pours out legislative initiatives on everything from light bulbs to vacuum cleaners to TV sets, which will apply to the EU?
Nobody knows - Nobody is allowed to know.
By research reports and other roundabout ways (eg who sits on the DG Energy C3 Committee on Energy Efficient Products) one gets to know some likely names on the Commission side - but that's it.
They don't even seem to have a secretariat. At most they have an email address type "tren-ecodesign@ec.europa.eu" but they never reply.
You might as well be dealing with the Cosa Nostra.

Much the same with these Consultation Forums.
Again, by various reports one finds out some likely representatives.
The Commission can rightly say that it's up to National Governments, Trade Organisations and Energy Saving Associations to decide who they want to send to represent them.
But that does not excuse saying afterwards who attended - after all, they have a monitored, named guest list of all who attended.
It's not as if it was the Ku Klux Klan attendance list. Presumably there is no shame/reluctance in name revelation.

The point is this: The Commission has sole rights to initiate legislation in the EU - presumably those selectively invited are invited to give valued input into this, and presumably they would not attend otherwise.
They should therefore stand by what they say - openly.
It's not good enough to say "by contacting the organisations concerned, they may say who was sent".
No real minutes are revealed (see the summary type below), no real information about what was discussed or who said what.

That's not all.
In any voting procedure, only the overall result is given. Not even the names of countries/organisations (as applicable) voting for/against, let alone reprentatives themselves.

Compare with equivalent launching of consultative forums or hearings in say the USA, or in individual European countries at least of the Western democratic tradition.
I have covered US Senate Hearings, similar to the EU Consultation Forum in having invited representative participation - that's even televised (C-Span) or retrievable by video. Video!!!
If any EU Commission hearing even had summary minutes released by someone, he or she would probably be crucified within minutes up on the Berlaymont.


The following shows replies I recently received looking for information.

They suggest looking at vacuum cleaner legislation as an example (this was before the light bulb review).
Vacuum cleaners of course will also soon be limited in energy use, so expect to spend twice as long cleaning up and use the same energy anyway.

Members of the Regulatory Committee are representatives of Member
States of the European Union (EU). A list of the persons who
participated in a particular meeting is not published on the EU’s
‘EUROPA’ web portal.

You may want to contact directly the Permanent Representations of the
Member States to enquire about whether the names of delegates in a
particular meeting are available. You can find the relevant contact
details on the EU’s ‘whoiswho’ portal at the following URL:
http://europa.eu/whoiswho/public/index.cfm?fuseaction=idea.hierarchy&nodeID=3780&lang=en

Furthermore, you might be interested to know that by consulting a
Summary Record of one of the Ecodesign regulatory Committee, you can
find at the end of the document the Ministry/Department/Agency which
represented the Member State in that particular Committee meeting
[Ecodesign Committee has the reference: C07900]. An example is the
meeting of 27/02/2013 on vacuum cleaners:
http://ec.europa.eu/transparency/regcomitology/index.cfm?do=search.documentdetail&F8O7DquaYsFIjeSNfyvxNCwAqN39eC+0fCcDkqDDB/sxdbQ+AI/X9VTTMRqv00VG

We hope you find this information useful. Please contact us again if
you have other questions.

PDF documents below, in case not seen:
Document 1
A typical Ecodesign meeting's summary report and (as here) a brief voting record

Document 2
A list of typical national ministries and agencies represented (anonymously)











How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

Lamp Guide Site: Environment

Also given the recent posts commenting on EU light bulb laws:
A good Lamp Guide.
Aside from much well illustrated practical advice, it also covers health and environmental issues.


Below: the environment section should be viewable








How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

EU Commission Light Bulb Ban Review 5: GWL: 12 Good Reasons to Keep Halogens

Update 27 November. Original post 26 November

For a preliminary report of the November 25 Consultation Forum meeting regarding the commencing review of EU light bulb regulations and involving the EU (European) Commission, national energy efficiency representatives and lighting "stakeholders", see the post published earlier.

Here is another alternative view of the light bulb ban, and of the current issue of allowing halogens or not:
Greenwashing Lamps, like Rik Gheysens in the last post, once again usefully complements what was said in the comments to the first Commission proposal post in the series, this time with a very visual perspective.

The Greenwashing Lamps blog post itself summarizes the proposal. Then it links to the pdf document as also reproduced below (alternative copy).


12 Good Reasons for keeping Tungsten Halogen






A text-only extract of the last sections of the above, themselves well illustrated in the original:

9. Lifespan
• CFLs may, under optimal cicumstances, last from 5 000 to 15 000 hours depending on model.
• LEDs are often claimed to last 20 000 hours or more. A clear advantage when long life is desired.
• Halogen lamp life is typically 2 000 hours for standard models. However, it is quite possible to make halogen lamps that last 10 000 hours. Such lamps already exist on the market.
• Standard incandescent bulbs typically last 1 000 hours, but can also easily be made to last up to 20 000 hours by simple improvements to sensitive parts. Such lamps already exist (in the U.S.).



10. Lower Environmental Impact
New research in January 2013 by scientists in California and South Korea found that:
“The CFLs and LEDs have higher resource depletion and toxicity potentials than the incandescent bulb due primarily to their high aluminum, copper, gold, lead, silver, and zinc.
Comparing the bulbs on an equivalent quantity basis with respect to the expected lifetimes of the bulbs, the CFLs and LEDs have 3–26 and 2–3 times higher potential impacts than the incandescent bulb, respectively.”

Halogen Eco lamp (simple to make and recycle)
• Quartz glass & soda-lime glass
• Tungsten (wire filament)
• Molybdenum, copper, iron or nickel (metal/wires)
• Bromine or iodine (halogen gas)

CFL-i (complex to make and recycle)
• Soda-lime glass
• PBT or PET (brominated polymer) plastic housing
• Nickel-plated brass base
• Aluminum, copper, nickel, tin and/or zinc base or wires
• Lead oxide, aluminium oxide
• Barium/aluminum oxide compounds, manganese (phosphor mix)
• Lanthanum, yttrium oxide or phosphate (rare earths)
• Mercury (vapour or amalgam)
• Lead (solder)
• Krypton-85 (gas)

LED lamp (complex to make and recycle)
Anode, cathode, semiconductor crystal, ballast, socket transformer, capacitor, controller, heat sink, LED module, bulb and base may contain:
• Soda-lime glass
• PMMA, PBT or PET (fire retarded/brominated plastic)
• Aluminium (heat sinks and housings)
• Nickel-plated brass (lamp bases)
• Bauxite (glass and adapters)
• Copper (adapters and wiring)
• Lead (glass and adapters)
• Nickel, zink (adapters)
• Tin (adapters; glass coatings)
• Lanthanum, yttrium oxide, manganese, barite (phosphor mix)
• Semiconductors (depending on colour): Arsenic, boron, gallium,
indium, phosphate rock, selenium, zinc

Low-lumen LEDs (= majority of LEDs available for the home market) use as much precious resources as high-lumen lamps but for very little light. LEDs are most effective when over 800 lumens and used for many hours per day. They are not suitable as low-lumen lamps as the light quality is too low.




11. Different Lighting Technologies
All lighting technologies have their advantages in different situations.
• Incandescent & halogen lamps, where light quality is most important, e.g. at home, in fashion stores, galleries, restaurants, hotels etc.
• CFLs, LEDs, fluorescent tubes, HID lamps where light quantity is of higher priority than quality, e.g in offices, corridors, garages, or as outdoor lighting; when lighting is turned on all day or all night.

Incandescent and luminescent light sources are not interchangable.
They have very different technical properties and light qualities. No matter how much luminescent (phosphor-based) light is improved, it can never be the same as fire-based light, anymore than brass can ever be gold, or rayon silk. It’s a different product; superficially similar and useful in other ways, but still not the same.

A CFL can often be replaced by an LED or metal halide HID lamp of the same colour temperature and socket. They are all phosphor-based and have similar CRI and light quality.

A frosted incandescent lamp cannot be replaced by a CFL or frosted LED without changing and lowering the light quality, or by or clear halogen without changing functionality.
A frosted incandescent lamp can only be replaced by a frosted halogen lamp for the same glare-free top quality light.

A clear halogen lamp cannot be replaced by a CFL or LED without lowering the light quality and changing functionality.
Clear halogen A-bulbs, R7 tubes, G4 and G9 mini bulbs have no replacements.




12. Health & Wellness
Light is an essential bio-nutrient, just like water, food and air.
Physiologically, light regulates hormones. Visually, it helps us see well when there is no daylight.
Psychologically, it is one of the most potent mood enhancers at the disposal of an interior designer, home maker or professional lighting designer.

A clear, top quality, naturally dimmable light that is not too cold or dull, is of essence in order to be able to see well and relax in our own homes at night.
Banning halogen lamps is like banning silk or cotton and forcing everyone (including those who are allergic to them) to use only synthetic fibre because the latter fabrics are considered more durable.
We all want to save the environment, but there are many other ways to easily save the little that could theoretically be gained by banning halogen lamps.


  [there are plenty of reference links to the below points in the pdf document, not coded in here]
All currently available lamps are needed, except CFLs and high pressure mercury lamps which can and should be replaced due to mercury risk, and ‘cool white’ (light blue) LEDs which may harm vision and disrupt sleep hormones.

• Standard halogen Eco bulbs must remain available for those:
- who need bright light of good quality in order to see well (= most people over 60)
- who prefer or need the highest light quality (= many women, artists, photographers etc)
- who have light-sensitive eye- or skin conditions (= c. 25% of the population?)
- for whom CFLs may be hazardous due to mercury spill risk (children & pregnant women)
- for whom LEDs may be hazardous due to blue light risk (= children & people with ARMD)

• As there are no top quality frosted replacements, frosted halogen A-bulbs should be permitted again for those who are sensitive to glare (= e.g. many seniors, migraine patients etc).

• And as there are no good quality replacements for the R7 tubes and, G4 or G9 halogen mini bulbs, these must remain available for those who have invested in costly halogen downlight, floodlight, spotlight, or dimming systems because they wanted the best light on the market.

So please let EU citizens be free to choose from an open market what type of light quality they want to use in their own homes.

Thank You!

How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

EU Commission Light Bulb Ban Review 4: Rik Gheysens

Update 28 November with extracts and comment section   Original post: 25 November

To continue the reaction to the EU proposals as detailed previously, some other voices, as promised.

Belgian researcher Rik Gheysens has a good bilingual website (version in Dutch here) with plenty of documentation, particularly on fluorescent lighting and problems.
Includes an excellent extensive EU Q and A section, with questions put by EU MPs to the Commission also on the light bulb ban in general, and the answers received.

He has in the last week also covered the light bulb ban review in depth with a critical analysis - which in many ways complements the comments made here in the earlier post, in going more deeply into CFL and mercury issues and also LED environmental problems.


As should be seen below, the press release document (pdf, alt copy). If the view looks messy, try clicking on it to reduce the internal page size etc (seems to work differently in different browsers and their various versions).
As always, downloading the document may work better.






Comment

While much focuses on CFLs and mercury - and for the understandable quoted reasons - it is my belief that the Commission and lighting companies are actively moving away from such lighting: The recent Commission proposal, as linked above and in the document itself, hardly mentions CFLs and the LightingEurope (Philips, Osram, GE etc) statement as previously posted also entirely focuses on the "Ledification" of society.

This is likely also borne out by Commissioner Oettinger's statement, as in the document:

Answer given by Mr Oettinger on behalf of the Commission

The regulation is to be reviewed by 2014.
That will be the time to consider how the EU framework for energy saving lighting should be further developed. In the meantime, the Commission would draw the Honourable Member's attention to the fact that, under Directive 2011/65 (2), the mercury content of Compact Fluorescent Lamps (CFL) in the EU was halved as from January 2013 to a maximum of 2.5 mg (compared to 50 milligrams in cell batteries and 500 milligrams in amalgam dental fillings)

Halving the allowable mercury content makes fluorescent lighting still harder to make with acceptable performance for a given price - which perhaps is the intention, moving towards a "de facto" ban, just as with energy usage standards on incandescents, without actually calling it a "ban".
Personally, while understanding the health, environmental and other arguments against fluorescent lighting, I find it a shame to ban any lighting, and I remain (very) unconvinced that the Commission is doing this out of some bleeding-heart-sympathy-for-consumers.
The greater profitability including self-admitted heavy EU subsidisation (see EU proposal) of LED manufacture has the Commission-Manufacturer tandem working nicely again.


The LED section of the document should therefore also be noted.
Again good points, with plenty of new references not used in this blog before.
As for health, environmental and light quality issues with LEDs, also see the preceding posts in this blog, with illustrations and references.

Some slight editing of the below quote:

Light-emitting diodes

- These lights have a continuous spectrum.

- They have a CRI of only 80-85. Nick Farraway, international sales manager at Soraa, wants a CRI of 95 or greater. But he agrees that it will be difficult and at high costs. [http://ledsmagazine.com/features/10/10/10]

- They have a power factor of 0.5 –0.9 for lamps between 5W and 25W.

- They contain rare earth metals.

- They have a very complex manufacture and the disposal needs special measures.

- They have a spectral imbalance within the blue:
The white light of LEDS has generally a blue peak, which makes it unsuitable to use it at evening. Medical research indicates that blue light is very effective in reducing naturally occurring human melatonin levels. The real impact of light depends on three features: color, intensity and duration.
Melatonin secretion is reduced to 50% after:
  - 403 hours of exposure to an monochromatic RED light at 100 lux
  - 66 min to a candle
  - 39 min to a 60W incandescent bulb
  - 15 min to a 58W daylight fluorescent lamp
  - 13 min to a pure white high-output LED
(Angeles Rol de Lama, e.a., Contaminación lumínica y salud: El lado oscuro de la luz, Dpto. Fisiologia, Universidad de Murcia)

- SCENIHR [ed- the European Commission Scientific Committee on Emerging and Newly Identified Health Risks, link] shows the following opinion:
Despite the beneficial effects of light, there is mounting evidence that suggests that ill-timed exposure to light (light-at-night), possibly through circadian rhythm disruption, may be associated with an increased risk of breast cancer and also cause sleep disorders, gastrointestinal, and cardiovascular disorders, and possibly affective states. Importantly, these effects are directly or indirectly due to light itself, without any specific correlation to a given lighting technology.(SCENIHR, 2012, p. 59)We disagree with this last sentence.

- When dimming a LED,some problems may arise.
(More information in Review study, p. 71-72)

- The lifetime of the LEDs depends on the temperature of the junction and the electric current intensity, without forgetting the quality of production and integration. At present, the definition of the lifetime of a LED and the measuring method are not standardized.
(Effets sanitaires des systèmes d’éclairageutilisant des diodes électroluminescentes (LED), Rapport d'expertise collective, Octobre 2010, p. 40)
The heat is "enemy No. 1" of LEDs, more specifically of white LEDs. LED operation at too high a temperature (and therefore high junction temperature of the semiconductor) has a dramatic effect on efficiency but also on other characteristics and performance of LEDs such as the flux, the spectrum (and thus the color), the polarization voltage, and the life. To take advantage of the interesting properties of LED (flux, efficiency, durability, quality of light emitted), integrators must take into account the heat generated by the LED and qualities of this component to evacuate the heat.(Ibid., p. 207)

- High luminance: (i.e. the high brightness density per surface unit emitted by these very small sources.) LEDs are point sources of light that can be aggregated in lighting units to achieve high luminous flux. Because the emission surfaces of LEDs are highly concentrated point sources, the luminance of each individual source produces very high luminance, at least 1 000 times higher (107cd/m2) than that from a traditional lighting source.

- Stroboscopic effect: Depending on their architecture, the electrical power supplied to LED lighting systems can vary, causing fluctuations in the intensity of the light produced that are more or less perceptible to the naked eye.
(Opinion of the French Agency for food, environmental and occupational health & safety in response to the internally-solicited request entitled "Health effects of lighting systems using light-emitting diodes (LEDs)"19 October 2010)

- The number of EU citizens with light-associated skin disorders that would be affected by exposures from CFLs was estimated in the report to be around 250,000. Clearly, the risk for this group of patients is not limited to CFLs, but includes all light sources with significant UV/blue light emissions. The lack of proper data precludes any improvement of the estimate of the size of the affected group.
(SCENIHR, 2012, p. 11) It is a shame that without further knowledge of the effects of LEDs, the precautionary principle is not applied.

- Because the lemon and primrose yellow are extra sensitive to blue and green, it is risky to illuminate some artworks with LEDs due to the high proportion of blue light. LEDs can damage the paintings of great masters!
(Dutch newspaper De Volkskrant, 4 January 2013)

- The luminous efficiency of LEDs was estimated between 4.2 and 14.9%.
[https://en.wikipedia.org/wiki/Luminous_efficacy#Overall_luminous_efficacy]

How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

EU: Allow Frosted Halogen Bulbs!

Last update 24 November. Original post 22 November

Earlier posts in this series have dealt with the EU review of the light bulb ban, with the details of the EU proposal concerning the future of halogens in the first post.

Recent very good comments on other websites, which I will expand on shortly, include:
• Rik Gheysens with a special press release (pdf, alt copy). This complements earlier posts here in particularly covering the health and environmental effects relating to CFLs and LEDs.
• The Greenwashing Lamps contribution, again with documentation (pdf, alt copy) including well laid out photographic comparisons of using LEDs compared to Halogens, showing the latter in a much better light, as it were.


Clearly the position of this blog is that restrictions on all lighting and indeed other products should be lifted, which are not connected with danger in their use but simply to reduce energy consumption, itself better achieved in other ways.

But the focus at this time is on halogens:
The initial part of the review process deals with the stage 6 proposed ban on remaining halogen replacement bulbs.
As seen from the posts, it seems likely that at least some halogen lighting will be allowed to continue:
But if so, the type of allowed bulbs should be considered.

Specifically, the ban on frosted (non-clear) halogen and similar energy efficient incandescent bulbs should be lifted.
Frosted (matte, pearl) light bulbs and their more opaque (white, opal, soft-tone) varieties generally go by the name "non-clear" bulbs in legal EU terminology:
In comparison with clear, transparent light bulbs the brightness in lumen output and thereby the energy efficiency varies slightly depending on the luminescence of the coating and its thickness, 5-10% either way.
That is, frosted bulbs can be brighter than clear varieties.

The EU research report itself mentions this, by one of the consultants behind it.

Paul van Tichelen replies that we have to make distinction between clear and frosted equivalent.
A clear lamp is always in the lower lumen output.
The lamps we found with above 800 lumen output were for frosted lamps (higher lumen output than clear lamps).

[Note: "(higher lumen output than clear lamps)" albeit emphasized, is the original quote, it is not a comment addition]
Clear LED lamps as referred to more commonly have lower brightness than clear incandescents in comparison with their respective alternatives, but the overall point remains.

The outsider might therefore be reasonably perplexed why the EU - and the EU as sole worldwide jurisdiction - banned frosted lighting in the first place.

Frosted bulbs are, or were, the dominant form of incandescents desired by consumers, especially in Northern Europe (90% of pre-ban incandescent sales, Philips/Osram data). They spread the light more evenly and reduce the point-source glare of clear bulbs.

As always, the irony of popularity making Commission people happier to ban, for supposed greater savings.
No point in banning what people don't want to buy!
Accordingly, in their memorandum to the original 2009 legislation, the Commission stated that those "who want non-clear lamps can buy CFLs and LEDs", presumably feeling that it would help push people to those lighting types, and ignoring all other aspects of why a particular form of lighting is chosen.

But the case here remains a peculiar one.
At least the bans on regular incandescents (and certain TV sets, washing machines, vacuum cleaners, etc)
are straightforward "legitimate" bans in terms of energy efficiency standards.

The ban on frosted bulbs, in this case halogens, is pure Orwellian social engineering, without justification in itself,
and without comparison in any other countries.
Will that make the European Commission think again, on the grounds of (shock, horror) showing some magnanimity to consumers and their choices?
Is the moon a balloon?




Making a "light connection" to add to the above...





As always, when politicians and their bureaucrat cronies come up with petty pointless bans, people will try and get around them.
Hence, in this case, the famous (infamous) euro-condoms, as thought up by lighting designer Ingo Maurer, and as covered in earlier posts on this blog:

Screwing the EU with a Condom
Screwing the EU with a Condom... again



How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

EU Commission Light Bulb Ban Review 3: LightingEurope Industry Statement

Continuing the series on the EU Light Bulb Ban Review.

Recap
The first post covered the details of the review of the 2009 light bulb regulations that has been started by the EU (European) Commission, and the Commission's proposed 2 year delay on the stage 6 phase out of halogen replacements.

The second post covered the lighting industry position ahead of the EU proposal, mainly that of the major LightingEurope stakeholder (Philips, Osram etc), where they advocated a 3 year delay.
As seen, the representatives were unhappy about cheap lower quality LED imports, hoping for stricter rules in the meantime, rather than being particularly keen to maintain a halogen (let alone standard incandescent) choice for consumers.
My comments criticized this accordingly.

Of course, a few representatives do not necessarily speak for the whole association.
In any case, as per the subsequent released official position of LightingEurope on the issue, they advocate abolition of the stage 6 phase out, and are certainly supportive of halogen lighting alternatives.

An outsider would consider this completely normal:
After all, what manufacturer normally welcomes a ban on what they can or can't make?
Yet, as the history of regulation shows, the major manufacturers have hitherto done just that, on the basis of forced switchovers to more profitable alternatives. A cynical view is that allowing halogens is a magnanimous meaningless gesture to the manufacturer profit bottom line (halogen replacements being far more expensive than regular incandescent bulbs for marginal usage savings, and they were unpopular as a mains voltage choice while regular incandescents still existed). But at least it maintains more choice for consumers.


Should be seen below as a scrollable PDF document:
LightingEurope position on the review of the Stage 6 Requirements of Commission Regulation (EC) No 244/2009

Commenting follows below.






Comment

Conclusions

LightingEurope welcomes Commission’s proposal to postpone the entry into force of the stage 6 requirements. Nevertheless, the LightingEurope recommends the abolishment of Stage 6 requirements, allowing LED technology
to mature further and to grow to a level of market penetration that made it a viably alternative for all EU citizens after having reached an optimal point in terms of monetary and energy savings, without compromising jobs.

Clearly welcome.
Interestingly, as seen LightingEurope is also critical of the Commission suggestion to ban special R7 and G9 halogen types, and to enforce LED compatibility on new fixtures - as covered in the updated first post in this series.



The main argumentation, extracts, inserted comments in italics:

Impact on European Consumers
Each technology produces light with a different distribution pattern.
Halogen lamps are omni-directional point sources,
CFL lamps are omni-directional diffuse sources,
LED chips are directional point sources.
[All lighting forms have their own advantages..indeed]

Luminaires designed for halogen lamps are generally designed for omni-directional point sources.
Other lamp types may or may not function properly in a luminaire in a specific application.
[Note the implied criticism of the EU proposal to enforce LED compatible fixtures]

It is up to the user to determine whether or not a CFL or LED replacement lamp is acceptable.
[An extraordinary statement, for anyone who has read their past communications]

In many applications they are acceptable, but in many other applications they are not.
It needs to be pointed out in this context that learnings from the phase out of incandescent lamps that started in 2009 should be taken into account when determining stage 6 requirements. Upholding these requirements or even postponing them to only 2018 would lead to a factual and unintended phase-out of well established and demanded products on the European lighting market. [Implied objection to EU regulatory rule - again extraordinary - hopefully the authors of this don't get sent to Siberia or whatever the equivalent EU punishment is... and it continues:]
It is to be expected that the consumer’s outrage might be comparable to the one in 2009.
In some applications, a halogen lamp is required for the luminaire to function properly in terms of light emission, quantity of light, light distribution, dimmability, heat management and quality of emission.
If no halogen lamp is available anymore, the only other option is to completely replace the luminaire which would have a severe negative economic impact on the consumer.

Reasonable estimations from industry side indicate that more than 200 million luminaires [fittings etc] in European households would factually become unusable under implementation of stage 6 requirements.
Given this, also a transition period until 2018 would give only five years to European consumers to replace their luminaires.
In the end (costs minus savings) until 2025 consumer would have costs for replacing luminaires of 1.9bn€!
Together with the additional costs €3.1 to €4.6bn caused by a ban as calculated in Table 19 of the review study (p. 40) the overall costs for the keeping stage 6 becomes: €5 to 6.5bn until 2025.

A ban of mains-voltage halogen lamps could have a negative effect on future savings...if consumers are
forced to use CFLi / LED as early as 2016, sockets will be blocked to further improvements of energy efficiency for the next 10/25 years

Savings in 2020 Abolishing stage 6 vs keeping stage 6 and moving to LED: 18.6-9.2= 9,4TWh
Savings in 2020 Abolishing stage 6 vs keeping stage 6 and moving to stage 6 MV-HL: 18.6-14.1= 4,5TWh
Savings until 2060 abolishing stage 6 vs keeping stage 6 and moving to LED: 252,9-218,4= 34,5TWh
Savings until 2060 Abolishing stage 6 vs keeping stage 6 and moving to stage 6 MV-HL: 221,9-218,4= 3,5TWh

They understandably still welcome LED development of course...

LightingEurope is convinced that the increasing “ledification” of light and the related disruptive changes to the entire lighting sector should be seen as opportunities for the European lighting industry.

As a critical aside, to what is obviously otherwise a surprisingly positive statement:
To the extent a push for LEDs might be backed by campaigns, subsidies and maintained existing regulations as on regular incandescents, one might ask if that means a ledification....or leadification of the light bulb sector
Both literally and metaphorically.

Literally in the lead content of LEDs
Department of Chemical Engineering and Materials Science, University of California, USA analysis:
Excessive levels of copper (up to 3892 mg/kg; allowable limit: 2500), Pb (up to 8103 mg/kg; limit: 1000), nickel (up to 4797 mg/kg; limit: 2000), or silver (up to 721 mg/kg; limit: 500), rendering all except low-intensity yellow LEDs hazardous....

Metaphorically, in dulling down a lighting industry, by decreasing rather than increasing choice and competition between different technologies (also by focused subventions on LEDs to the exclusion of alternatives) leaving the LEDs as some sort of sole saviour of humanity.

Bluish LED light forms are already taking over as car headlights, bicycle lamps, torches (flashlights), and at this time, Christmas lights - and not always with a pleasant or even useful light quality.

LED development, in overcoming some of its disadvantages, is welcome and useful - but not to the exclusion of all else.
All lighting has advantages and disadvantages.
It is good and welcome that Philips, Osram and others are beginning to recognize this.
If they haven't quite "seen the light", they have at least shown some "illuminating" development.
 


Finally,
any continued allowance of halogen lighting should include frosted, softer tone (EU term "non-clear") light bulbs, needlessly banned along with all other such incandescent bulbs. They were by far the most popular bulbs before the ban, with less point source glare.
It might be said that stage 6 only deals with already specified halogens. But - as from the EU Commission's own proposal ("extending the stage 6 requirements to halogen lamps with G9 and R7s socket") this does not hold up: the Commission themselves already added clauses, in terms of banning GP and R7s socket bulbs, and in mandating LED compatibility of new fixtures.
So clearly (or non-clearly!) they could move to alter stage 6 requirements to allow such halogen light bulbs.

Even in the underlying research report, the point is made by one of the consultants behind it that such light bulbs are often more - not less - energy efficient than the clear transparent bulbs

Paul van Tichelen replies that we have to make distinction between clear and frosted equivalent.
A clear lamp is always in the lower lumen output.
The lamps we found with above 800 lumen output were for frosted lamps (higher lumen output than clear lamps).

[Note: "(higher lumen output than clear lamps)" albeit emphasized, is the original quote, it is not a comment addition]

Clear LED lamps as referred to more commonly have lower brightness than clear incandescents in comparison with their respective non-clear alternatives, but the overall point remains.
Frosted brightness will depend on luminescence and thickness of coating in being more or less energy efficient. Overall, it is a marginal issue, as also acknowledged by the EU Commission:
The original ban argument that "people can buy CFLs/LEDs if they want non-clear lamps" obviously ignores all the other reasons why particular lighting is chosen.
The EU legislators often say they are not the only ones banning bulbs.
But no other jurisdiction than the EU maintains such a petty specific ban on frosted light bulbs.



How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.
 

EU Commission Light Bulb Ban Review 2: Lighting Industry Views

See a previous post which covers all the details of the review of the 2009 light bulb regulations that has been started by the EU (European) Commission.


LEDs Magazine is an excellent USA based publication covering mainly technical issues relating to LED lighting.
While obviously supportive of LED development (and why not), the October article covering the upcoming EU review of lighting regulations was surprisingly critical of the EU phase out - as were the industry representatives interviewed, although obviously from a perspective of their own eventual successful sales.
A delay of the halogen phase-out to 2019 is proposed, which as it happens is close to the EU proposal of a delay to 2018.


Regarding LightingEurope, the industry association covered in the article, quoting from their website introduction:

LightingEurope is an industry association representing leading European lighting manufacturers, national lighting associations, and companies producing materials. We are committed to innovation, sustainability, quality and leadership. We contribute to shape policy and establish industry standards and guidelines.
We are dedicated to promoting efficient lighting practices for the benefit of the global environment, human comfort, and the health and safety of consumers [and our profits].

If incandescents were so bad, then they could of course just stop making these "terrible" bulbs!
Manufacturers change standards all the time - without government bans.
"Unfortunately" someone else would of course then make the cheap popular bulbs.
Hence the irony: if incandescents were not so popular, there would be no "need" to ban them.

Incidentally, it is perfectly alright and even to be expected, that GE, Philips, Osram et alia lobby for a ban on patent expired cheap generic popular incandescents for their own profits from expensive patented alternatives.
The issue is with politicians - and people like the EU bureaucrats - handing them profits on a plate, to the detriment of consumers and their free choice, and with little if any overall energy saving for the extensive reasons provided elsewhere here (see pages on the left), which also answers "green" concerns in terms of which bulbs are actually "green".


Below article:
Energy efficiency may come at the cost of consumer confidence
Caroline Hayes, LEDs Magazine October 2013

Comment

LightingEurope believes that no LED-based lamps will meet the Stage 6 requirements of European Commission (EC) Regulation 244/2009.... LightingEurope advocates that 2019 is a more realistic date for halogen bulbs to be replaced, rather than the current deadline of 2016. There are several reasons for this request: affordability, a desire for consumer choice, and quality issues....
Jürgen Sturm, secretary general of Lighting­Europe, is concerned that an accepted technology is taken away with no viable alternative offered...

A delay is better than an immediate ban, and overall the conclusion is welcome, although if LEDs "keep getting better and cheaper" then presumably consumers would want to buy them - voluntarily - without bans on alternatives.

Why the eternal assumption that we, as consumers, are idiots?
And why the assumption that we are idiots because we may think (Shock, Horror!) that lighting products should primarily be judged on lighting ability.


As it happens, it's hardly out of worry for consumer choice that the manufacturers want a delay - rather that there are still too many cheap alternatives that might, er, distract consumers from their own expensive wares...

[Jürgen Sturm]...the fear is that halogen bulbs will be phased out before the market is mature, leaving low-quality LEDs to be seen as the only option, based on prices. This will be detrimental to the maturing market, Sturm warns...
A related issue is that there is no provision for what Sturm calls "market surveillance." Each EU member state is to be responsible for policing the pricing and quality of LED replacements. What is affordable in Sweden may be unacceptable in Romania, for example, he points out. The lack of market surveillance in member states is a particular worry for LightingEurope...

[Nick Farraway]...there will be many products imported without quality controls and sold alongside the expensively produced ones.... consumers, buying cheaper brands, are left with a poor impression of LED lighting.

A worry then that cheap (Chinese) imports will displace profits from their expensive bulbs - with an ominous call for market surveillance.

It is perfectly understandable that a maker of a quality product does not like that his/her product might get a bad name from rival manufacturers making cheaper, worse, similar ones.
If technical specifications are not met by the imports there is obviously a legal case as well, and imported bulbs like all bulbs should meet whatever the label holds on lifespan and other criteria.
But regulating "quality" is a questionable business - and the manufacturers seem to have regulation on the brain.

There is a market, and there is an ability to sell: Show it, folks.

Market surveillance is needed for dangerous-to-use products.
If market surveillance is called for here, why doesn't Big Gov stop people buying anything cheap and shoddy.
Hey, ban fast food - expensive high quality food is better for us!
Hey, ban cheap batteries and washing up liquids - so we only buy the good expensive alternatives!
(Which are advertised as such of course "expensive to buy but cheap in the long run" and/or otherwise in having better performance quality - and which light bulb manufacturers could too, instead of crying like this all the time).

This is also of course similar to why incandescents were banned in the first place (getting cheap popular competition out of the way).
It is also similar to the "call for shop inspections" by a sympathetic Commissioner Oettinger, to get rid of the legal rough service incandescents that people again "unfortunately" might buy.

For hotels and commercial installations, the payback period should be 6–12 months, but for homes, where lights are used less, the payback may be extended to a period of 3–4 years, which is not such an obvious financial return for consumers.

Well, well. There's an admission.
Although 3-4 years is still far too low for the infrequent usage of most household bulbs (average 20-25 bulbs per household in the EU, more in North / West European households) - as covered elsewhere here.
Longer time still, when taken as the unsubsidised payback cost per LED to the taxpayer.

For Farraway, there are other flaws in the EcoDesign Regulations.
One is that the low specified CRI (color rendering index) may deter end users from LED lamps. Halogen lamps are popular with consumers because they render color well, he says, enhancing interiors. He is concerned that the EU is allowing quality to be diluted.

He fears lessons have not been learned from the introduction of energy-efficient compact fluorescent bulbs. "Compact fluorescent is a good technology to save money, but is a poor light, and therefore unpopular," he says, referring to its green hue. He wants a much more stringent color metric for replacement bulbs. The EU wants 80 CRI, but Farraway wants 95 CRI or greater, although he concedes that the obstacle to this is a more difficult and more costly process technology.

While recognizing the central issue all bulbs have advantages - as it happens, incandescents have a maximal Color Rendering Index of 100 - it's hardly "progress" to push for expensive LED clones in such respects.
CFLs and LEDs have advantages other than CRI.
Imposing incandescent-style CRI standards just shows how messed up the regulatory thinking is - by all sides concerned.

[Farraway]...the price will decrease as volume increases for an affordable product that can last 40,000 hours, compared to an incandescent bulb's 700 hours.

700 hours?
If your associates didn't stick with Phoebus cartel standards for household consumers - and even that is 1000 hrs - then they could last 20,000 hrs and more, as per Aerotech and other incandescent bulbs for industry.
Conversely, the lab specificed 40,000 hr life is doubtful on several grounds in real life (including the dimming with age of LEDs) - and even the EU Commission's own VHK/VITO research report uses 20, 000 hrs.




How Regulations are Wrongly Justified
14 points, referenced:
Includes why the overall society savings aren't there, and even if they were, why alternative policies are better, including alternative policies that target light bulbs.