The Odd Green Crony Capitalist Coalition Behind Banning Bulbs

January 7 article by Shawn Regan, from Reason.Com
Good on the industrial policy behind the ban

Lights Out For America’s Favorite Light Bulb
Happy New Year, America! Your favorite light bulb is now illegal.

Well, sort of. As of January 1, U.S. businesses can no longer manufacture or import “general service” incandescent bulbs—the most popular light bulbs in America. Consumers can still buy and use them while supplies last, but the remaining inventory won’t be around for long. Home Depot says it will be out of the bulbs within six months. Some consumers have started to stockpile.

It’s all part of the energy efficiency standards mandated by the Energy Independence and Security Act of 2007. The law already killed off the 100-watt incandescent bulb in 2012, followed by the 75-watt bulb in 2013. Now, in the final step of the phaseout, the minimum efficiency standards have effectively banned the ubiquitous 40- and 60- watt light bulbs.

When industry and environmental groups claim that a regulation will solve all problems, consumers beware. It’s probably green cronyism in disguise.

The ban is crony capitalism in its most seductive form — when it’s disguised as green.

Major light bulb manufacturers supported the ban from the outset.
The profit margin on old-style bulbs was pitifully low, and consumers just weren’t buying the higher-margin efficiency bulbs. New standards were needed, a lobbyist for the National Electrical Manufacturing Association told Congress in 2007, “in order to further educate consumers on the benefits of energy-efficient products.”

So Philips Electronics and other manufacturers joined with environmental groups to push for tighter lighting standards.
As the New York Times Magazine explained in 2011, “Philips told its environmental allies it was well positioned to capitalize on the transition to new technologies and wanted to get ahead of an efficiency movement that was gaining momentum abroad and in states like California.” After much negotiation, a classic “bootleggers-and-Baptists” coalition was born. Industry and environmental groups agreed to endorse legislation to increase lighting efficiency by 25 to 30 percent.

Incandescent light bulbs, we’re told, are vastly inferior to the newfangled alternatives available today.
The compact fluorescents lamps (CFLs), LEDs, and halogen bulbs are an apparent no-brainer: They last longer and convert much more of their energy into light rather than heat, all while cutting back on your energy bill. (So, of course, the government must stop you from ever making the mistake of choosing the traditional bulbs.)

Except many consumers aren’t buying it.
The EPA estimates that, of the four billion light-bulb sockets in United States, more than three billion still hold incandescent bulbs. “By 2014, the traditional incandescent light bulbs… will be virtually obsolete,” claimed a 2007 press release from former Sen. Jeff Bingaman, the ban’s original sponsor. But according to the latest industry data, incandescents still make up nearly 65 percent of all U.S. light-bulb shipments.

Many consumers are turned off by the higher upfront costs of the alternatives.
A single 40-watt LED bulb costs $7.50 or more, while a traditional incandescent bulb goes for around 40 cents. Some are finding that the CFLs don’t last nearly as long as their supporters claim—especially if they are switched on and off frequently, or if they are attached to a dimmer switch.

The list of complaints about the “efficient” bulbs goes on:
They are often slow to respond, sensitive to high temperatures, and can cast a harsh and unattractive tone. CFLs also contain a small amount of mercury, which requires extensive and careful cleanup when a bulb breaks.

And they may not be saving us much energy after all.
The typical U.S. home uses no less energy per capita than it did in the 1970s, despite an onslaught of efficiency standards for everything from refrigerators and televisions to the amount of power consumed when appliances are in “standby mode.” The money saved in the long run by using these appliances is often spent on even more power-sucking gadgets. And if light bulbs cost less to use, why not just leave the lights on longer?

The light-bulb ban is an example of how political coalitions are formed to force regulations on the general public that benefit a few large producers.
A recent survey found that six out of every ten Americans are still in the dark about the latest bulb ban. Meanwhile, the dimwitted light-bulb policy just became the law of the land.
The lesson here is straightforward: When industry and environmental groups claim that a regulation will solve all problems, consumers beware. It’s probably green cronyism in disguise.

Shawn Regan is a research fellow at the Property and Environment Research Center (PERC), a nonprofit research institute in Bozeman, Montana, dedicated to improving environmental quality through property rights and markets.

This complements a January 1 article by Tim Carney at the Washington Examiner.
Tim Carney has for several years covered the industrial policy behind the USA ban.

Industry, not environmentalists, killed traditional bulbs
Say goodbye to the regular light bulb this New Year.

For more than a century, the traditional incandescent bulb was the symbol of American innovation. Starting Jan. 1, the famous bulb is illegal to manufacture in the U.S., and it has become a fitting symbol for the collusion of big business and big government.

The 2007 Energy Bill, a stew of regulations and subsidies, set mandatory efficiency standards for most light bulbs. Any bulbs that couldn't produce a given brightness at the specified energy input would be illegal. That meant the 25-cent bulbs most Americans used in nearly every socket of their home would be outlawed.

People often assume green regulations like this represent the triumph of environmental activists trying to save the planet. That’s rarely the case, and it wasn't here. Light bulb manufacturers whole-heartedly supported the efficiency standards. General Electric, Sylvania and Philips — the three companies that dominated the bulb industry — all backed the 2007 rule, while opposing proposals to explicitly outlaw incandescent technology (thus leaving the door open for high-efficiency incandescents).

This wasn't a case of an industry getting on board with an inevitable regulation in order to tweak it. The lighting industry was the main reason the legislation was moving. As the New York Times reported in 2011, “Philips formed a coalition with environmental groups including the Natural Resources Defense Council to push for higher standards.”

Industry support for the regulations struck lawmakers and journalists as a ringing endorsement of the regulations. Republican Congressmen Fred Upton, who has since flip-flopped and attacked the regulations, cosponsored the light bulb provision in 2007. His excuse, according to conservatives I spoke to: It couldn't be that bad if the industry supported it.

Liberals used this very argument to ridicule Republicans' 2011 efforts to repeal the law. Democratic congressman Steny Hoyer defended the rule by saying, “The standards are supported by the lightbulb industry.”

Joe Romm at the Center for American Progress pinned repeal efforts on the “extremist Tea Party wing of the party, which opposes all government standards, even ones that the lightbulb industry itself wants.”
That “even” signifies that the industry’s support indicates consensus. Instead, it signifies how consumers lose.

Competitive markets with low costs of entry have a characteristic that consumers love and businesses lament: very low profit margins. GE, Philips and Sylvania dominated the U.S. market in incandescents, but they couldn’t convert that dominance into price hikes. Because of light bulb’s low material and manufacturing costs, any big climb in prices would have invited new competitors to undercut the giants — and that new competitor would probably have won a distribution deal with Wal-Mart.

So, simply the threat of competition kept profit margins low on the traditional light bulb — that's the magic of capitalism. GE and Sylvania searched for higher profits by improving the bulb — think of the GE Soft White bulb. These companies, with their giant research budgets, made advances with halogen, LED and fluorescent technologies, and even high-efficiency incandescents. They sold these bulbs at a much higher prices — but they couldn’t get many customers to buy them for those high prices. That's the hard part about capitalism — consumers, not manufacturers, get to demand what something is worth.

Capitalism ruining their party, the bulb-makers turned to government. Philips teamed up with NRDC. GE leaned on its huge lobbying army — the largest in the nation — and soon they were able to ban the low-profit-margin bulbs.

The high-tech, high-cost, high-margin bulbs have advantages: They live longer and use much less electricity. In the long run, this can save people money. But depending on your circumstances, these gains might be mitigated or eradicated.

The current replacement for traditional bulbs are compact fluorescents (those curly bulbs). They give off UV rays, contain mercury gas, take a while to get bright and don’t last any longer than regular bulbs if you flip them on and off a lot.

Newer technologies, like LED bulbs, are better than CFLs, and they supposedly last 20 years. But they cost even more. In your office building, they probably make sense. In your house? Well they won't last two decades in a house full of kids who wrestle with the dog and throw footballs around the living room (maybe Congress should ban domestic wrestling and passing).

There is a middle ground between everyone using traditional bulbs and traditional bulbs being illegal. It's called free choice: Let people choose if they want more efficient and expensive bulbs. Maybe they'll chose LEDs for some purposes and cheap bulbs for others.

But consumer choice is no good either for nanny-staters or companies seeking high profit margins.

Technologies often run the course from breakthrough innovation to obsolete. Think of the 8-track, the Model T or Kodachrome film. But the market didn’t kill the traditional light bulb. Government did it, at the request of big business.

Timothy P. Carney, The Washington Examiner's senior political columnist, can be contacted at tcarney@washingtonexaminer.com His column appears Sunday and Wednesday on washingtonexaminer.com.

Comment

A lot more on the industrial policy behind the banning of light bulbs in the USA, Europe and elsewhere: http://ceolas.net/#li1ax
Specifically in an American context, also the "I Light Bulb" eBook by M.P. Leahy and Howard Brandston.
Howard Brandston, a well known New York lighting designer, was involved from the start in recurrent Senate hearings, and has covered the strange workings of the NEMA sub-committee (Philips, GE, Osram/Sylvania) in seeking the USA 2007 ban and indeed in their seeking to uphold it through 2011 (and no doubt 2014) reviews and bill attempts at tightening legislation further. His specific webpage and campaign against the regulations: http://www.concerninglight.com/commentary.html

The major manufacturers not unnaturally want to sell more profitable patented expensive alternative bulbs, and feel that any obstruction would be reneging on "promises" by politicians to smooth the way for them through initial consultation and legislation as per 2007 US law, 2008 Canada law, or 2009 Australia and EU laws.
Philips, GE, Osram/Sylvania cooperated to ensure incandescents did not have more than 1000 hour lifespan (the Phoebus cartel) and then cooperated to get rid of them altogether. Slam-Dunk.



Paul Wheaton

Note the irony:
Any outsider would of course consider it unusual that manufacturers would voluntarily seek to legally limit what they are allowed to make, and to welcome such laws once they are made.
The manufacturers are therefore repeatedly lauded by perennially clueless journalists for their "great green conscience", and of course happily strengthen such an image in their press releases.

Somewhat more perceptive observers remark that the manufacturers could have voluntarily stopped making the bulbs, just like they stop making much else in the name of progress - but that would therefore have allowed small and new and local manufacturers to happily and profitably make the patent expired generic cheap bulbs, without global distributive overheads or commitments to expensive alternatives.

In turn misunderstanding the process, "progressive green" people claim that legislation was necessary or the manufacturers would "never" have stopped making the old bulbs.
Apart from ignoring that incandescent lighting might have light quality and other advantages beyond crass economic or energy use reasoning (and the supposed savings not being there anyway as per other argumentation), this ignores what "progress" is: and it is hardly expensively imitative replacement clones of incandescent bulbs.
Increased - not reduced - competition drives progress, and it is conveniently forgotten that CFLs and LED bulbs were invented in the presence - not the absence - of incandescent competition, moreover that new inventions can always be helped to market albeit without continuing subsidies, allowing the best alternatives to flourish, with "expensive to buy but cheap in the long run" advantages highlighted by imaginative advertising, as is done for other products.

Overall it is of course odd to ban popular safe products just to reduce electricity consumption.
There are plenty of ways to reduce say coal use or emission or electricity, whether by legislation or taxation, and plenty of informative possibilities to say encourage lighting to be switched off rather than to ban a particular choice of it.

There is nothing but idiocy behind this banning of 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.
 

Canada to adopt more US Laws beginning with Light Bulbs: Losing Industry, Jobs and Choice, with Hardly any Savings

Last updated December 23
Update info: Campaign against the ban by Federal MP (Government Conservative party) Cheryl Gallant of Ontario, blog post about it (December 23).
Also Section 1 of the Document revised, consequent (P7 version) updates also done to Doc and PDF links below.


The below constitutes 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

Email: equipment@nrcan.gc.ca Telephone: 613-996-4359
John Cockburn, Director Equipment Division Office of Energy Efficiency Natural Resources Canada CEF, Building 3, Observatory Crescent, 1st Floor
Ottawa, Ontario Fax: 613-947-5286
But best to also contact local media etc. Media very quiet on this.


What Canadians are not being told about January 1 2014 Light Bulb Regulations

Enforcing US Law:
Losing Independence, Industry, Jobs and Choice,
with Hardly any Savings and Hardly any Halogens.


In a seemingly hastily written October proposal, just in time to invite standard 75 day comment by December 19
(leaving little time for any subsequent serious analysis, should perchance the Cabinet be interested in doing so),
Canadians are told that by aligning to USA standards Halogen bulbs, similar to regular incandescent bulbs, will not be banned.

They will.
And that's just the start.


1. Why Alignment to USA will also ban Halogens
The supposedly allowed Halogens banned on USA EISA tier 2 2014-2017 backstop final rule equating to CFL standard. Following Washington means following any other change they make. Proposal already envisages further restrictions.
2. What is good for Canadian Industry, Jobs and Consumers?
Light bulbs stated as the first of more US laws in manufacture and service to harmonise NAFTA standards. Allowing US based corporate access does not mean having to legislate against local production to local desire.
3. How Incandescents have particular Advantages for Canadians
Beyond heat, also brightness, and situational advantages in large homes where much time spent
4. Simple Incandescent Advantages versus Halogens
Halogens more complex and expensive for little savings advantage, hence unpopular in free choice either with consumers or politicians.
5. On Energy saving for the Nation
Fractional overall and on comparative policies, and a main off-peak time use avails of surplus production capacity anyway.
6. On Emission saving for the Planet
Ditto, with the addition that Canada has 86% emission-free electricity and that emissions may increase on heat replacement effect
7. On Money saving for the People
Ditto, with the addition that free choice is not always about money saving, that many bulbs are not often used, and that subsidies plus utility compensation may mean higher bulb and electricity payments anyway via tax or electricity bills.
8. Worldwide Policy and Major Manufacturers
Cooperation to enforce low lifespan on incandescent bulbs followed by cooperation to altogether ban such now patent-expired generic cheap competition. Plus ça change, plus c'est la même chose.
9. Alternative Policies targeting Light Bulbs
Information, taxation/subsidy and market competitive alternatives could and should be considered before bans.
10. Incandescents - the Real Green Bulbs?
Efficient, earth saving, long lasting and sustainable.
The simplest way to produce bright light from electricity banned for being too popular, by the stupidity that passes for global governance.

Full version:  As Doc    As PDF
Parts 1-3 reproduced below



1. Why Alignment to USA will also ban Halogens

USA Energy Independence and Security Act of 2007/Title III/Subtitle B/Section 321

"The Secretary of Energy shall report to Congress on the time frame for commercialization of lighting to replace incandescent and halogen incandescent lamp technology"

A backstop final rule relates to a cycle of rulemaking that will start in 2014.

" BACKSTOP REQUIREMENT— if the final rule [not later than January 1, 2017] does not produce savings that are greater than or equal to the savings from a minimum efficacy standard of 45 lumens per watt, effective beginning January 1, 2020, the Secretary shall prohibit the sale of any general service lamp that does not meet a minimum efficacy standard of 45 lumens per watt"

As the Energy Information Administration at the Department of Energy puts it, the second tier of energy efficiency improvements “at the latest becomes effective by 2020, essentially requiring general service bulbs to be as efficient as today's CFLs"


The stated main purpose of the current light bulb proposal is to align with US legislation.
Comparatively, the original MEPS legislation can be seen at SOR/94-651 part 1 Items 136-139 with luminous flux based definitions (unfortunately not shown or linked in the proposal). The US wattage based regulations were previously deliberately avoided, citing several disadvantages with the US system including less bright bulbs being allowed in place of brighter ones, usage of higher wattage class defeating the purpose etc. This is not mentioned now in changing standards.

The proposed adoption of USA law is justified as facilitating company product development and distribution to a bigger market, now and in the future, and is to be followed by similar adoption of US law for other products for the same reasons.
With light bulbs a further highlighted beneficial effect is said to be that American standards will allow incandescents in the form of Halogens, albeit still with differences to simple incandescents and a lot more expensive.
However, not only would some higher energy efficiency halogen types not have been banned anyway under the originally proposed legislation, but as seen current USA legislation bans all incandescent technology including touted halogen replacements for general service lighting, EISA tier 2 2014-2017 45 lumen per Watt final rule which equates to fluorescent bulb standard. Replacement Halogens at 18 lumen per Watt, 20-22 at best, are way below that.
The notion that manufacturers would improve halogens falls on commercial consideration (as they at length explained in the November 25 EU meeting and documentation), and for example Philips already quietly dropped promised EcoVantage development once the 2009 EU ban had been achieved.

Aligning with US legislation of course means that guarantees about what will or won't be allowed can no longer be given.

To reply that
"Canada will just adopt the first (USA Tier 1) levels and won't ban Halogens even if the USA does",
is not in keeping with proposal's purpose and argumentation of aligning with USA standards in the first place, including the specifically stated supposed advantages of suppliers not having to deal with two standards for products.

Notice also that 45 lumen per watt is a minimum standard and is set to be followed by others (USA background documentation talks of Tier 3 in 2020).
Notice also that these are and would be technology-neutral standards.
So the splitting up of different products for distribution becomes more difficult anyway, and of course all the more so should further USA rules not be to Canadian taste.

45 lumen per watt is as said based on fluorescent lamps that are going out of political favour, and the hitherto mercury-exception of fluorescent lamps may come to be abolished, if they don't disappear from markets beforehand given recent decreases of allowable mercury levels in some jurisdictions like the EU, which make them less commercially viable to sell.
Of course those who criticise bans on incandescent bulbs might be pleased, should the CFL (fluorescent, "energy saving") bulbs disappear. But that would be on top of banning incandescents, and would hardly happen until other replacements have found political (if not popular) replacement favor.

The big noise in the world of lighting regulation is "Ledification", Japan aiming for a total switch by 2020 and the European Commission in current talks with manufacturer representatives in dealing with the timing of banning halogens and pushing a LED switchover.
[LEDs certainly have energy efficiency advantages, but are also very difficult to make as bright omnidirectional incandescent bulb replacements at low prices, along with having a number of health and environmental concerns of their own as covered later. The simple fact is that all lighting types have advantages and disadvantages, and bans of any should surely be approached with caution. The main distinctive technology advantages are of incandescents as bulbs, fluorescents as long tubes and LEDs as sheets - which is also how the latter 2 were first developed]

Notice how all this is applicable to any aligning to allow Washington to dictate what Canadians can or can't buy, and which may or may not be to Canadian taste, not just with light bulbs, and not just with energy efficiency regulations, given the stated ambition to expand such regulatory alignment and favour multinationals in their North American product development and future distribution of products (see section 2 on industry policy below).

Alternatively, the Canada Government knows about and plans a future ban on halogens.
It is after all true to say that "halogens will still be allowed" - for now.
They would also be doing exactly what USA, EU, and Australia ruling officials did before them:
Wave funny bulbs around to visibly show they were "doing something" about global warming, while "assuring" everybody that "lookalike halogens" to traditional bulbs would still be allowed
It would also seem strange if Canadian lawmakers did not know US law before shifting to it.


The proposal finishes, perhaps with admirable openness:

"...over time, it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS [Minimum Energy Performance Standards] for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."

Put the frog into boiling water - it jumps out.
Put the frog into cold water and keep heating it - the frog is cooked
"How to Cook our Canadians"

So, Canadian Cabinet...how about the Canadian public not being duped about "what is allowed"?


In this regard, one should also be aware of how regulations are coordinated and arranged to achieve a desired purpose (read, ban completion).
Jurisdictions like Canada, EU, USA and Australia are in close contact as seen from background documentation to legislation and international meetings between energy agency officials and major manufacturer representatives.

Regulations are therefore divided into Tier 1 and Tier 2 processes.
The original 2012 Canada plans also had a Tier 2 2015 phase-out intention.
Staggered implementation is of course understandable in cushioning the effect both for manufacturers and consumers as new technology is introduced.
However that also allows - or should allow - unbiased monitoring of the effects on consumers of lighting availability and quality, and that supposed energy saving actually takes place.
But follow-ups are no fun for politicians - promises are. The typically and suitably long-term savings projections also apply for Canada (2025, see the proposal annex) allowing catchy quotable big savings figures, and then to say "Well, buddy, we'll check on that in 2025"! Brilliant - the decision makers long since having retired.
Suggested evaluation based on just measuring assumed savings from how products have been adopted (handy for the backing companies, who don't have to pay for that research themselves!) is hardly the same - and misses the overall consumer impact.
In BureaucratSpeak, "stakeholders" aren't any guys and gals strolling around Queen Street in Toronto.

Both the EU and the USA have 2014 review processes:
These should therefore have meant a neutral assessment of Tier 1.But as the continued bans are already written into legislation, the reviews are mainly about alternative lamps and possible change in the timing of Tier 2 implementation. Talk about a 1-way street.

As for the USA, it's not just that halogens are legislated to disappear sometime before 2020. The Obama administration in cooperation with the Democrat controlled Senate Energy Committee already tried to tighten lamp and other energy efficiency regulations in 2011. But as with many bills, it did not make it through Congress. Lowering the standards requires Congress passage, and the President's signature. Hardly anytime soon.

A further possible reason why the officials writing the laws want Tier 2 bans already legislated in place, is the difficulty and nuisance of having to revisit the issue in public or parliamentary debate.
US law is of course already difficult to alter as just noted, and this applies also in the 28 nation and multi-institutional EU.

Canada is different, and could be different, in openly considering what is right or wrong, and not just for multinational corporations.


The proposal here does commendably invite public comment....
but why is it kept away from Canadian Parliament for debate, all the more so since proposal comment finishes Dec 19, with MPs already being off looking for turkeys and tourtières on the 13th and not back until Jan 27?
The government cabinet rubberstamping American legislation into place over the holiday period surely sets a bad precedent if it hasn't done so already, given the mentioned ramifications.


The bigger picture about the light bulb regulations is not any guarantee about halogens.
The bigger picture is about why light bulb ban regulation is necessary in the first place - and particularly in Canada.

Canada has no obligation to ban either halogens or simple incandescents.
This was shown in already delaying ban implementation.
Canada is - still - an independent country.
If it is not in the interest of Canada, Canadian business, Canadian jobs, or Canadian consumers to ban lighting products on other than safety grounds, then it should not be done.

And it isn't...




2. What is good for Canadian Industry, Jobs and Consumers?

"This proposed amendment would support the Government’s regulatory policy of aligning with American standards, where feasible"
"it is anticipated that the proposed standards would help to increase the level of acceptability for MEPS for many Canadians, thus facilitating the adoption of further MEPS for these and other products in the future."
"compliance risks are much less than they would be if Canada had unique standards. Canada would benefit from the compliance regime that is in place to support U.S. standards."

Adoption of US standards for many more products - not just concerning energy efficiency - is set to continue.
The US dominance on the North American market hardly means Washington adopting Ottawa standards.

This does not just sideline Canadian autonomy for its own sake.
It means no longer making products to specific Canadian demands, should they conflict with American desire.

So, should the border just be shut, to only have "Canadian products for Canadians"?
No, the point is not the protectionism angle.
The point is that allowing American standard products in Canada, does not mean having to ban products made to specific Canadian demand and desire.
Manufacturers can still make American standard products both for internal market or export, as they wish.

Presumably if the American standard is so attractive for the major multinationals for market reasons, then they'll make to that standard, and leave the smaller specific Canada demand to Canadian suppliers.
They don't "have to suffer regulatory burden by making products to 2 standards", as the proposal basically puts it.


This is therefore about a lot more than light bulbs, it is about any product that because of climate, geography, culture, or other reason might be of value to Canadian consumers.

Legally, in a case of regulatory conflict between the Canada and USA standards,
if a Canadian requirement is deemed less stringent, that is obviously not a problem - the point here.
If a Canadian requirement is more stringent, perhaps on environmental or safety grounds, that is still justified on Canadian rights as a sovereign country.

The Government proposal at hand is overly focused on helping major manufacturers sell in both countries, repeatedly stating so.
Maybe some more widespread consideration is justified.

Yet even on such narrowly defined market-minded economic justification for bowing to Washington, the question is if it's a good policy.

To keep adopting US standards will likely cost Canadian supply and distribution jobs,
especially of already existing standards as supply and distribution to those standards is already well established on the bigger US market, but also of simultaneously applied standards, as larger US based suppliers simply extend the reach for their products.

Conversely, while still allowing such free trade movement of goods,
the freedom of manufacture to local needs gives local jobs and locally satisfied consumers.
Also if Americans are not making or distributing such products then clearly all the better for Canadian jobs.


Turning now specifically to energy efficiency regulations, such as on light bulbs,
the relevance of what has been said is even greater, on several counts.

Firstly, by adopting US legislation, USA based control becomes even more likely - after all, their manufacturers and distributors have had regulatory knowledge and established implementation for several years on any such regulatory shift. With the light bulbs, that's 7 years knowledge and 2 years implementation for the US rivals.
After all, the proposal makes much of how manufacturers prepare for standards in advance (and, conversely, if anything, Canadian suppliers prepared for the wrong MEPS standard).

Secondly, how big is current and assumed future Canadian light bulb production anyway?
While I have been unable to find figures (and, again, the proposal could have supplied them!) it presumably mirrors the USA and EU in dominant Chinese CFL/LED imports and dwindling local incandescent/halogen manufacture.
Maybe it's great to help the Chinese (as also outsourced by Philips. GE or Osram-Sylvania) but surely not of utmost importance, and on the distribution side that again comes down to likely American control on a unified market for reasons given.

Thirdly, with energy efficiency regulations it need not be USA versus Canada standards.
Not having energy efficiency regulations in the first place opens up to true manufacturer freedom without the "regulatory burden" that the proposal worries so much about.
That obviously need defending of itself, and will be done for light bulbs, but one should also be well aware of what it would mean for industrial policy and jobs, given the industry focus in the proposal.

The tone of the proposal is of abandoning regulations with threatened chaos.
But it is just to continue without implementation, and with manufacturer and consumer freedom.
A freedom that allows the start up of making popular bulbs, that hasn't hitherto happened given threatened regulation.


The popularity of bulbs to be banned (phased out, regulated..) is hardly in doubt.
If they were not popular, there would be no "need" to ban them and celebrate the supposed savings.
There are in fact many reasons why it is both easy and attractive to set up local small/new Canadian manufacture and sale with associated jobs of traditional light bulbs.
Firstly in being popular, as mentioned.
Secondly in being simple and easy to make.
Thirdly in being generic patent-free bulbs without licensing requirement from major manufacturers (now guess why GE/Philips/Osram-Sylvania want those bulbs banned).
Finally, in being without competition from America, and with likely little competition from anywhere else - while always allowing alternative "energy saving" bulb manufacture and sale as desired on the market.
Canada could have a considerable domestic light bulb industry of incandescent lighting.
Can the same be said about CFLs or LEDs?



Responding to the idea that regulations might actually not be imposed, the proposal suggests:

"Canada could become susceptible to product dumping from manufacturers from other countries seeking to sell traditional incandescent light bulbs no longer permitted in their own country."

This repeats what they said 2008 in defending the first MEPS regulations.
But bans have now already been legislated in many other jurisdictions (rationale later) and the proposal itself emphasizes how manufacturers prepare for them.
So the notion that those guys have been stockpiling incandescents on-the-side, just to dump on Canada in case Canada does not implement a ban, hardly holds.
Besides, Canadians would get more choice, and would have to want to buy them in the first place - "terrible" if they can buy what they want?
Finally, any dumping problem can always be met by import controls - it does not necessitate, nor does it justify, banning what people want to buy.


Two further justifications are given for not abandoning regulations:

"Suppliers to the Canadian light bulb market have already made considerable investments in research, development and retooling to meet the MEPS as written in 2008.
Canadian retailers have begun selling, promoting, and educating consumers about more efficient bulbs."

As for Canadian retailers,
I am sure they would be delighted to sell whatever Canadians want to buy.
Educating about "efficient bulbs" - that presumably means bulbs efficient in producing bright light using few components?
No? Well, that just shows how politically correct language is defined - handily substituting "efficient" for "energy efficient"
(as with calling fluorescent bulbs "energy saving" bulbs:
Hello Mr Retailer, can I have one of those Energy Wasting bulbs please? Ah, gosh, thanks very much!)

As for suppliers to the market,
the odd notion is this invitation to cry for them when they now instead have full freedom to make and supply what they want - including the bulbs they prepared for.
Compare with if they had been busy preparing to sell a bulb that was then made illegal!

The manufacturers were perfectly free themselves to stop selling incandescents if "they are so bad for the planet", as their press releases keep saying, and the media keeps swallowing. After all - the same GE/Philips and other companies stopped making record players, cassettes, 8-tracks and much else in the name of "progress".
But "unfortunately", others would make the popular bulbs if they stopped!
No manufacturer/distributor should rely on bans on competition to shift product they presumably have some sort of confidence and ability to sell.
Besides, the big American market would still have the limited competition they want.

Moreover, if the suppliers were preparing for the Canadian standard, "MEPS as written in 2008" and it "is a burden to make and distribute to both American and Canadian standard", well, then the suppliers have been preparing for the wrong standard, with Canada Gov now pulling the rug from under their feet!
Also, the fact that simple traditional light bulbs are easy to make means those guys can easily "retool" and make them too, and have the limited competition from USA on that score as already described.
Don't cry for me, Argentina.


For deeper discussion of industrial policy and manufacturers, see section 8

Meanwhile, do these bulbs really have any value for Canadians?.....



3. How Incandescents have particular advantages for Canadians

First, a summary of general advantages of Incandescents, then particular advantages to Canadians, and afterwards, a look at simple incandescent advantages vis-à-vis Halogens.

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.
 

Preliminary Report: November 25 EU Consultation Forum

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?!




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.
 

EU Commission Light Bulb Ban Review: Proposal to Delay Ban for 2 years on Halogen Incandescent Lighting

With Updates and Additions. Last: 20 Nov
Original Post: 27 October.

Note: There are - and will be - several subsequent posts to this that lay out the position of LightingEurope (representing Philips, Osram etc manufacturers) and other interested parties. See the blog homepage for latest posts.
LightingEurope has come out for the abolishment of stage 6 to keep allowing Halogens - and is also critical of the Commission suggestions to abolish special Halogen G9 and R7s types, and to enforce LED compatibility of fixtures - more of which below, which now include the Lighting Europe position statements. The LightingEurope position is otherwise covered in a specific post.


This post is based on the Commission proposal from the 21st of October, to delay general service Halogen incandescent lamp phase-out by 2 years, part of an ongoing Commission review of EU light bulb regulations on general service lighting that began 2009 - more on the overall review below.

For a comprehensive rundown why the regulations don't make sense as a whole:
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.
 

The stated problem in the current Commission proposal is that while "B" class Halogen type replacements are technically possible they have not been found suitable (=profitable) enough to manufacture on any large scale. It is envisaged that the 2 year delay will, with plenty of public subsidies, therefore allow Philips, Osram, GE & Co to make LED products that will substitute for the 2 other major lighting types on today's market.

Thereby the envisaged end not just for incandescent lighting (simple or halogen type) but also for fluorescent lighting.
Fluorescents (CFLs) are conspicuously ignored in the paper and likely to come under increasing phase-out pressure, either from the removal of its current mercury content exemption, similar to already banned mercury containing thermometers, barometers and other products, or from a further reduction in allowable mercury, which effectively does the same (some mercury-free alternatives have appeared but not done well on the market, and further investment by major companies seems unlikely, as also per their industry response here, eg Lighting Europe).



The EU Review Process:
This is just the first part of the lighting ban review, dealing with "stage 6" i.e. general service Halogen specification.
The proposals will be discussed along with alternative suggestions on November 25 at a meeting in Brussels, open to "stakeholder" and other representatives from EU member nations, details below.
The overall review of the 2009-2014 ban will supposedly take place early next year in line with the 5 year review obligation as originally stated in passing the legislation, and ahead of a final consultation forum in April 2014.

However, updating this, some doubt seems to have been cast that further 2014 meetings will take place - it might just be left with this stage 6 review, in addressing light bulb availability.

Unfortunately the EU does not have great form in that regard, where the original regulation proposal never made it to the floor of the Parliament or to the accompanying media and public debate that might have taken place, debate (as it was) being cut short at the committee stage (How the EU regulated against incandescents, http://ceolas.net/#euban).
So those seeking to comment should not neglect to do it on that account.

Submissions suitably sent to the below:
Guenther.Oettinger@ec.europa.eu Gunther Oettinger, Energy Commisioner
Dagmara.KOSKA@ec.europa.eu Energy efficiency policy asst to commisioner Oettinger

Paul.Hodson@ec.europa.eu Head of Unit, Energy Efficiency,
Robert.NUIJ@ec.europa.eu Lighting efficiency in Paul Hodsons unit
Helene.RATEAU@ec.europa.eu Secretariat, records submissions

Ismo.Gronroos-Saikkala@ec.europa.eu, Head of Sub Sector, Energy efficiency of products
Ruben.KUBIAK@ec.europa.eu Overseer lighting policy
Andras.TOTH@ec.europa.eu lighting policy (ex-overseer)
Rasa.Pilkiene@ec.europa.eu secretariat, records submissions

UK submissions: Efficient.Products@defra.gsi.gov.uk
(DEFRA energy efficiency unit, EfficientProducts@defra.gsi.gov.uk also used)
Similarly to other EU national energy efficiency units of energy or environmental agencies, several of which can be seen listed at the end of the Consultancy Report linked below, together with the names of representatives.


EU Commission Suggestion 21-10-2013 amending Stage 6 of EC 244/2009
EU Commission Regulation 18-3-2009 EC244/2009 (original), alternatively copy here
VHK/VITO consultancy research report overseen by Rene Kemna, underlying the Commission recommendations.
The latter, in the Annex, includes Minutes of the last Stakeholder meeting on the review of Stage 6 Requirements, held Friday 26 April 2013, Berlaymont building, Brussels. The list of attendants is attached at the end of the document. Many will presumably also form part of the November 25 meeting, in the same building (November 25 draft agenda, no details, 10.00-17.00)


The Commission technical report underlying the phase-out of incandescent lighting, analysis of replacement lighting, and - at the end - the timetable of phase out dates and requirements September 2009 - September 2016
EU technical briefing on lighting phase-out and dates


The directive on conditions that replacement products must meet
Directive 2009/125/EC (alt copy here)

Extract:

Implementing measures shall meet all the following criteria:
(a) there shall be no significant negative impact on the functionality of the product, from the perspective of the user;
(b) health, safety and the environment shall not be adversely affected;
(c) there shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle cost of the product;
(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.

Recommended Changes to the Regulations

Following the outcome of the review process, the Commission proposes to begin the revision procedure with the aim of adopting amendments to Regulation 244/2009 and Regulation 1194/2012.

The recommended regulatory changes include:
1. changing the entry into force of the stage 6 requirements to 1 September 2018, allowing LED technology to mature further and reach an optimal time point in terms of monetary and energy savings;
2. removing the current loophole by extending the stage 6 requirements to halogen lamps with G9 and R7s socket;
3. and introducing a provision that luminaires sold after 1 September 2015 should be compatible with LED technology to prevent future obstacles to efficient lighting

Top Images: (Left) Halogen G9 socket capsule   (Right) G9 Socket adapted for regular bulb use
Bottom Images: (Left) Halogen R7s socket tube   (Right) R7s Socket adapted for regular bulb use

































Regarding the proposed delay on banning general service mains voltage halogens:

While the likely delay is welcome, it should be made a permanent exemption.
The already marginal society energy savings are still smaller. It would also have shown some magnanimity in terms of consumers and their lighting choices.

In any case, temporarily or permanently, the EU should allow frosted (non-clear) halogens, a petty ban without energy saving justification, on the basis, from the underlying EU memorandum, that people "who want non-clear lamps can buy CFLs and LEDs", ignoring all other aspects of why a particular form of lighting is chosen.
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).

In fact frosted lamps, apart from reducing glare, ironically may have slightly higher brightness = more energy efficient (depending on luminescence and thickness of coating).
As one of the consultants behind the EU research confirms in their report:

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 point remains, and energy efficiency differences were as said never a ban motive]

Conversely: Any general ban of mains voltage halogens removes the last possibility of using clear transparent burning filament lamps, with their unique "sparkle" effect in lanterns, chandeliers etc, unlike clear LED clones.
ENEA Italy comment in the consultancy report adds CFLs

CFL-i are, by definition, nonclear lamps, so their use as a substitution for clear lamps is in principle wrong...
Diversification of the market offer is very important.

The Commission likes to justify its actions with respect to what other countries are doing, more about that here.
Perhaps it's just a co-incidence that Canada just watered down its proposed regulations, specifically stating that it is to allow Halogens, having delayed implementation by 2 years in the first place.
Moreover, USA and Australia and other comparable jurisdictions which do have the similar intention of phasing out Halogens, do not engage in the specific EU petty ban on frosted (non-clear) Halogen types.





Regarding "closing the loophole" of G9 and R7 socket lamps:

The technical review study reveals that the exception of certain halogen lamps with a G9 and R7s socket from stage 6 creates a loophole, which some manufacturers have already started exploiting with adapter-kits.
These adapter kits allow consumers to use G9 socket halogens with a wide range of other sockets and are already available today. Given the low price of these adapter kits, in conjunction with the small retail price of G9 halogen lamps, it is likely that this loophole could significantly undermine the success of the stage 6 requirements as a significant portion of consumers might choose the presumably 'cheaper' option while paying more through non-realised energy savings.

Yes, how terrible if people are allowed to use what lighting they want!

Lighting choice is not just about what is cheap or what saves money in usage (and even if it was, so what?).
Plenty of other expensive product alternatives are marketed and bought for specific advantages.
"Expensive to buy but cheap in the long run" advertising sells woollen clothes, washing up liquids, batteries... without manufacturers lobbying for bans on cheap alternatives.
All lighting types have advantages for different situations:
"Switch all your bulbs and save money" campaigns are like "Eat only bananas and save money" campaigns.

Little consideration of light quality and other factors that also influence personal choice - as is obvious from their document which focuses on energy and cost in relation to lighting and the types that can relevantly be made on the basis of metered electricity usage alone.

Also see answers to specific sections below.

Update:
LightingEurope (the major industry stakeholder representing Philips, Osram etc) in their position statement (as also covered in Post 3 of this Light Bulb Review series) is firmly against any action against these halogen types:

LightingEurope does not identify a real loophole in the exception of certain halogen lamps with a G9 and R7s socket from stage 6, nor the assumption that this loophole could significantly undermine the success of the stage 6 requirements in terms of energy savings.
In the view of LightingEurope, the Commission working paper gives too much relevance to so-called adapter-kits for these types of lamp sockets and draws a picture as if these adapters are sold in high volumes. According to the market observations of the European lighting industry, there is only one manufacturer of these adapter-kits and the availability in retail, and subsequently the presence on the market, is limited.
The adapter together with a bulb costs between 8 and 11 Euros, making it a niche product for special applications. It would appear to be doubtful to base the argument of including G9 and R7s into the requirements of stage 6 on the evaluation of a small market segment.
In addition to the huge negative impact which would arise if G9 and R7s socket halogen lamps would not be on the market anymore, no replacement would be available to consumers.

Regarding future compatibility with LED technology:

Some luminaires currently on sale are not compatible with future solid-state technologies, creating a 'lock-in' effect to old technologies such as halogen lamps. This might happen through design options limiting the dimensions of possible replacement lamps too much, or through the inclusion of functional elements such as control gear not compatible with LEDs. This creates an unnecessary obstacle to efficiency improvements and a burden to consumers. It is therefore crucial for the wide-spread acceptance of LEDs – and the overall transition to energy efficient lighting – to guarantee that new luminaires are ready for the future.

Notice the overall big emphasis of LEDs throughout.
The CFL replacement scenario - so dominant in 2008/2009 decision making - is not "cool" anymore.

While some may welcome it, I am personally against coming mercury regulations that in practice will increasingly ban fluorescents too, which beyond CFLs come in many forms and useful types of such lighting.
I refer to 2 good blog posts on the issue on Kevan Shaw's blog:
International Mercury Convention Picks Wrong Lighting Target (Jan 2013)
In Praise of Fluorescent Lighting (July 2012)

As always, LEDs have their advantages and disadvantages too, fully covered elsewhere here.
However, once again, the EU Commission show their determination to get rid of "loopholes" like lamp sizes and fitting dimensions and control gear not being LED compatible - again reducing choice, on all criteria bar supposed energy usage.

Efficiency?
Does the Commission mean efficiently producing bright light by needing few components?
Probably not.

Update:
Again (see last section) the major industry stakeholder LightingEurope in their position statement, while acknowledging the Commission reasoning, ends up critical of the EU stance:

• LED is not the only efficient lighting technology and may not be suited to all applications (especially in the Tertiary sector).
• The development of LED lamps and modules is still very rapid and the availability of new/current products, even in 6 months’ time, is unknown. The format of new LED lamps and modules (even Zhaga) that will be
available in 2015 is unknown.
• The crossover of LED technology between the Domestic and Tertiary sectors means that even if the proposal is limited to just Domestic there would be an impact on Tertiary.
• Even if the proposal is limited to just retrofit lamps as covered by 244/2009, compatibility would need to be carefully defined as hidden issues such as thermal compatibility can negate any benefits and mean a LED product is not 100% compatible in all luminaires.
• The equivalence of compatible LED lamps need to be fully considered from an installation perspective e.g. LED tubes.
• A deadline of 1 September 2015 is very close in terms of product development cycles and meeting this deadline would be impossible in many cases.

Regarding the failure of manufacturers to make promised Halogens:

The technical review shows that it is possible to produce halogen lamps which would fulfil the minimum efficiency requirements of stage 6 (B-class). Indeed, B-class mains-voltage halogen lamps were previously introduced to the market, but disappeared shortly after due to alleged technical difficulties and high consumer prices. This left the market without any B-class mains-voltage non-directional halogen lamps.
The review indicates that the widespread (re-) appearance of B-class halogen lamps no longer seems likely to happen.
It is expected that manufacturers will not produce such lamps, because the necessary investments in new technology would not be economically feasible given the expected retail price of these halogens and the expected general market transition to LEDs.

The Commission says "alleged" :-)
Do they actually doubt the manufacturer stakeholders?
It's not too surprising if they do:
As some readers may know Philips, for example, promised spectacular Halogen bulb development (eg EcoClassic) - before the ban. Hence stringent incandescent criteria implemented by the EU.
Ban achieved, job done, and the promise of greater fluorescent (CFL) sales.

Also regarding Philips Halogen B class bulbs...from the consultancy meeting following the report (annex of report):

Paul van Tichelen replies that when he looks on-line he finds also some old webpages of the Philips lamps, but they are not produced anymore.
Kees van Meerten (Philips) can confirm that the lamp is already three years not in production anymore.

To some extent this has therefore come back to haunt the manufacturers - but only temporarily.
Now the new promise is of even more profitable LED sales, since fluorescent bulbs, conspicuously absent from any mention, will likely also become banned or at least "phased out" on the new EU mercury content regulation they were previously exempted from.
Of course, the regulations have still allowed interim profit making from the fluorescents, and the taxpayer subsidies relating to them.





Regarding LEDs as sole future lighting choice:

LED technology will likely be technically ready to replace halogen lamps in 2016. Currently, there are a number of limited functional deficiencies in LED colour rendering, or LED compatibility with dimmers and other lighting controls in existing installations. These can put consumer acceptance of LEDs as the sole replacement option for mains-voltage halogen lamps at risk. However, it is expected that technological development continues, removing these functional deficiencies while further increasing the energy efficiency potential and life time of LED lamps and reducing their costs.

"Expected" technological development?
Why not first make sure such development has occurred?
Having made one anticipatory mistake, the EU now proposes another.

They can hardly doubt that such LED development would occur with or without a Halogen ban, since they keep talking about "the expected general market transition to LEDs".
Significantly: "All stakeholders agree that abolishing the stage 6 requirements would postpone these job losses by a small number of years – it would not prevent them." "These job losses will happen in any case due to the market transition to LEDs."

The suppostion therefore is that LEDS will replace Halogens anyway without EU regulation, will replace incandescent bulbs, and will replace fluorescent (CFL) lighting; as seen, CFLs do not figure in Commission plans and current mercury content exemption of CFLs will likely expire.





Regarding the financing of LED development:

The Commission also provides financial support for research and technological development of efficient lighting solutions.
The development of solid-state lighting such as LEDs has been proactively influenced by Commission investments and research grants. The Commission's 2011 "Green Paper on Lighting the Future" highlighted research that was already receiving 135 million EUR of EU funding. The "Horizon 2020" will provide further investments to facilitate the development and uptake of LED technology in the EU.

Further financial instruments exist for cities to finance investments in sustainable and energy efficient infrastructure and products, including lighting, at local level.
Examples are the ELENA technical assistance facility12 and the European Energy Efficiency Fund (EEE-F)13. These instruments can be combined with 'Green Public Procurement', which allows authorities from Member States to concentrate public spending on efficient and environmentally friendly technologies.

The working paper then sets out a whole range of public funding support for LED production.
There is nothing wrong with this as such: It's good to see research support for any lighting development, and new products need help to come to market - "free markets" can't solve everything.

But the support for LEDs does not necessitate banning all the alternatives "to make way" for LEDs.
Yes, energy saving is good, but should relate to the overall picture of energy saving in society, and the many more appropriate ways to achieve it, including specifically in electricity generation, distribution and consumption: http://ceolas.net

Perhaps all this is foreseeable - I predicted this double whammy profit-making hand-over for manufacturers soon after original legislation (http://ceolas.net/#li1ax onwards). Note - appropriately - how Philips just a few days ago announced record profits from lighting division LED sales.

But Philips & Co should not be blamed for seeking profits - the issue is why profits keep being handed to them by EU officials.





Regarding "LEDs getting better, cheaper and more attractive":

Solid-state lighting such as LEDs and organic light emitting diodes (OLEDs) promises up to 20 times higher efficiency than the old incandescent light bulbs while offering over 25 times the product lifetime. With these advantages, it is expected that LEDs will soon dominate the market. Price levels in Europe are still high for LEDs. But they are falling and are expected to continue to do so (McKinsey14 forecasts price falls of 16% per year). The choice of an LED rather than a CFL currently pays for itself in 5 years. This is expected to decrease to 1.7 years by 2016 and half a year by 2020.
The arrival of LEDs and OLEDs [as light sheets rather than bulbs] continues to change the market.

Good - presumably people will want to buy LEDs then - without needing a ban to force such a choice.

Fervent pro-ban supporters rather shoot-themselves-in-the -foot on this one,
like the Danish Energy Agency in annex comments of consultancy report, urging a speedy ban on halogens:

During the last year, we have seen a worldwide 50 % price cut for LED lamps....the LED lamps have a much higher efficiency (energy class A or A+) and actually the prices have decreased remarkably... the predicted average efficacies 80 lm/W for 2017-20 and 100 lm/W for 2017-25 are all too low....
/ etc /

Then again - they could of course not urge a ban on the basis that LEDs weren't good enough!

Ergo.
A basic piece of logic for the legislators.
1. New bulbs are ever better, cheaper and more desirable
= Less reason to keep banning the old ones, little society savings, and they're still a choice for special use or need.
2. New bulbs are not great
= Again less reason to keep banning the old ones - obviously.

From the underlying research report (also linked in the introduction, above, MV = Mains Voltage):

Most experts agree that LED (possibly OLED) is the designated future replacement for MV-HL technology, but at the moment there are a number of technical/functional aspects such as colour rendering, dimmability, etc. and –most importantly-- the LED price that are potential barriers for consumer acceptance. These barriers are expected to be lowered to an acceptable level somewhere in the future, but the timing of forcing MV LED retrofits upon consumers is important.

Ah yes, consumers have to be "forced" to buy great products!
We are too stupid to make those right choices by ourselves.
If we were not so stupid, no ban would be needed for us. Thank you, EU people.

As the report agrees, price is not the only reason people buy light bulbs - besides, there is nothing wrong with products being cheap, and you don't keep buying cheap products that don't perform satisfactorily at the price.
As said, plenty of other "expensive to buy but cheap in the long run" products exist in the shops, properly marketed by manufacturers - when they don't run crying to the Commission, looking for quickfix bans.

Note how valves (vacuum tubes) are like incandescent bulbs, and how light emitting diodes are like transistors.
Questions..
If the EU of today had operated in the 1950's, would they have banned the "energy guzzling" valves too?
Would they have celebrated their effort on behalf of stupid citizens and the "wrong" choices they might make?
Would they have denied the world the unforeseen future niche use of these products (special audio equipment, guitar amplifiers etc).?

Pro-ban supporters say manufacturers change standards all the time.
Certainly: Philips, Osram and Co who cry about their environmental sensibility could of course just have stopped making incandescents themselves (the reason they didn't: ceolas.net/#li1ax).
Market product progress does not require Commission bans, and does not ban out-of-favour products for all time or for new manufacturers.

Progress?
There is something odd about all the "progress" talk in the consultancy report:
Drooling over retrograde LED clones of incandescents in the report annex that are "only" 20x as expensive at $12 or so (subventions not included).
One day, lighting progress might be discussed in terms of actual lighting advantages - not just in terms of lighting energy use.

All lighting has advantages, the comparatively greatest technology advantages being respectively
Incandescents - Bulbs
Fluorescents - (Long) Tubes
LED - Sheets (OLEDs)
RGB LED bulbs do have color temperature flexibility, but all the focus is on fixed warm temperature white phosphorescent LED incandescent clones. Progress my ass!

How are better products - and, yes, better energy saving products -actually made?
By increasing - not reducing - competition.
Energy saving products can still be helped to market - and the better priceworthy ones survive. Similarly if new manufacturers of incandescents were encouraged, then longer lasting incandescents also for domestic use could break the monopoly of the short lasting types by the market controlling major manufacturers (the Phoebus cartel involving Philips-Osram-GE fixed standard light bulb life at 1000 hours, penalizing those seeking to make longer lasting ones).

Commission President Mr Barroso likes to make polite noises about "cutting EU red tape and regulations".
Well, uncle José Manuel, you can start here.

In the consultancy report discussion as previously linked

Peter Bennich (Swedish Energy Agency) raises the option whether to abolish stage 6.

Well now Peter, there's a sacrilegious thought.
I hope you know your way out of the Berlaymont building.





Regarding environmental impact, related to energy and emissions:

The estimated environmental impact is in favour of keeping stage 6 in place compared to a scenario where such requirements will be lifted. Confirming the ban would yield annual electricity savings of approx. 9.4 TWh and related greenhouse gas saving of 3.4 MtCO2 equivalent by 2020. The accumulative savings up to 2025 are around 43.2 TWh in electricity consumption and 15.2 MtCO2 equivalent.

Nonetheless, keeping the current stage 6 rather than abolishing it is not the environmentally optimal solution. While predicting the make-up of the future lighting market is prone to uncertainty, the review showed that deferring the coming into force of stage 6 is on balance the best option. LED technology will still benefit from efficiency improvements after 1 September 2016. LEDs purchased in 2016 will not be replaced with more efficient ones for years to come due to their long life-time, slightly diminishing the overall savings potential of the LED technology. The environmentally optimal solution is thus a (limited) postponement of the stage 6 requirements.

The Commission proposal leaves out some of what the underlying consultancy report says...yes, the immediate savings are supposedly there from immediate ban or 2-year delay.
But the fact that LEDs have a long lifespan and continually becoming more energy efficient is held to mean that purchases after 2018 are likely to lock in still more energy efficiency and hence greater savings.

The consultancy report (their "less/negligible" emphasis in bold letters in the original text, not mine):

Over a longer period till 2060 (see economics section), the LED ‘lock in’ effect (long product life prohibits application of more efficient LEDs or OLEDs), the difference becomes less/negligible and it may even be in favour of the abolishing Stage 6 from the environmental point of view.

The "2060" date might surprise some:
But if LEDs are going to last 40-50 years (see the consumer use assessment data below), one is supposedly talking about 2058-68 before changing bulbs post 2018.
"Invest in an expensive LED for your grandchildren!"
Which ignores all the reasons one might prefer shorter lasting cheaper (dare I say incandescent) bulbs for less used lamps, or bulbs for temporary accommodation, or indeed bulbs for anyone aged over 30-40 in permanent accommodation.

As covered under Consumer Savings, below, there are several other reasons why more frequent bulb switching may occur, also in switching from old LEDs to newer LEDs, which after all supposedly become cheaper and more energy saving all the time, and are expected to become voluntarily preferable to Halogens (questioning the ban rationale in the first place).

Notice therefore:
Since all seem to agree that LEDs will continually become more energy efficient,
then whether or not there is a lock-in effect, stage 6 should be abandoned:
1. Lock in effect is there
= early bad stage 6 LEDs 2016 locked into 40 year use
2. Lock in effect is not there
= continually replaced LEDs means ever more energy efficient LEDs are put in place.


That's just the start of it.
The 2020 CO2 emission savings data uses EU Impact assessment data from 2009, as quoted in the consultancy report - and the data was old even in 2009 (I saw the original EU memorandum) yet it is still as seen dug out and projected far into the future for big easily quotable supposed savings:
Ignoring EU 2020 emission reduction initiatives and further 2030-2050 measures in the same vein.

The same applies to mercury emissions: The use again of old emission data projected to 2020-2030, still stating "coal plant mercury emissions from incandescent use are worse than CFL related mercury", ignoring the accord negotiations promoted by the EU with UNEP, finalised earlier this year (Brussels, 19 January 2013, Commission welcomes new global agreement to tackle mercury, here).
The mercury saving supposition did not apply anyway, again for many reasons).
The EU like the USA loves this kind of spin of dubious projections far in to the future to achieve catchy big numbers for gullible journalists and politicians to swoon by...


There are 2 ways of looking at the energy savings data.
One way is the above way - quoting huge figures to impress everybody.
The other way is to put those figures into context.
As from US Dept of Energy and EU institutional data, about 1% of grid electricity and a fraction of 1% of overall energy use is saved (further covered in the points rundown energy section)
Certainly: Still substantial in megawatt terms, but it therefore raises the perspective of relevance compared to all other ways of dealing with generation, distribution and society consumption, as extensively covered on the ceolas.net site.

The temptation is to say "Well every little helps".
Ignoring issues of consumer choice and that all lighting has different usage advantages,
that is questionable even on energy savings grounds - both in direct usage, and in overall life cycle terms.

When are incandescent lights actually used?
Mostly after 7pm (DEFRA, Intertek referenced), off-peak in generation terms - which is why electricity is cheaper - no reason to deny Johnny use of whatever bulb he wants on energy availability grounds (and 5-7pm peak period lighting is a miniscule fraction of use, heating, cooking etc coming on, and added peak generation is usually low emission gas or hydro anyway).

Now then.
Coal is by far the main CO2 (and EU) concern, and a finite fossil fuel.
Amazing fact: Light bulbs don't burn coal or release CO2 emissions.
Power plants might - and might not.

Perhaps an EU official could take 5 minutes to make a phone coal to their nearest coal power plant, and how they work?
Coal plants are "base loading", a permanent background source of electricity (unlike say wind power, without specific storage, which loses energy in back-to-forth conversion and so is not usually done).
Turning coal plants down and up has several maintenance cost issues, and while newer plants accommodate greater cycling, the operatively justified base load night cycle levels more than cover any consumer electricity demand at such times - which is also a reason electricity is so cheap then, on time-based pricing.
Lowering coal plant levels "to account for incandescent savings" (already small in grid demand percentage terms) is not an option given that operative levels are based on cost and wear and tear and slow stoking up to daytime use (see government and institutional references about this, as per above linked energy section). And that is even without looking at old Polish and similar coal plant operation.
This alone questions the whole energy-emission saving argumentation behind EU light bulb regulations.
So it's not just about sticking 2 bulbs beside one another on metered comparison and assuming power plant savings are equivalent!

But that is still not all.
No consideration is given in report or proposal to incandescent heat replacement benefit (Finnish, Canadian, UK, German studies (http://ceolas.net/#li6x) to CFL/LED power factor issues effectively using more energy on phase differential grounds (same site, or the energy sections of the regulation criticism page on the left here).


There is also the issue of reactive consumer activity:

1. Compensation
Arguably the biggest issue is dimness - 100W incandescent equivalent omnidirectional brightness is difficult with both fluorescents and LEDs (thus the irony of early 100W bulb bans).
On the one hand, using legal halogens slows any supposed savings of conversion to LEDs.
On the other hand, using more fluorescents or LEDs per lit area (with less lumen output per bulb) also negates the supposed energy savings.

2. Rebound
If a product effectively becomes cheaper to use, it will tend to be used more, a well-known "rebound" effect in energy efficiency circles.
There is no EU study I know about this, but as referenced on the Ceolas site, the town of Traer, Iowa, USA had consumption monitored in a switchover program of incandescent bulbs for free fluorescents. Electricity use increased by nearly 10 percent. Because running the new lighting was cheaper, the inhabitants apparently felt they may as well keep them on longer.
Fluorescent lighting may be slow to come on in the cold and is supposed to be left on anyway to increase lifespan, factors also influencing leaving them on and increasing usage.
Leaving light on may be seen to influence public and commercial activities more than domestic users:
Public and office buildings left lit all the time, albeit for security reasons and the maintenance cost of more frequently changing fluorescent lights that are switched on and off.

Chasing down Johnny and what light bulb he wants to use somehow seems even more absurd.



Then there are all the life cycle factors,
raising the whole issue of environmental sustainability:

Compare:
Simple incandescent products easily locally made with little energy or emissions and if need be long lasting of at least 20 000 hours (as for mining industry etc, eg Aerotech 2 dollar 100W 20 000hr bulbs), without recycling requirement.

With:
Complex rare earth mineral depleting patented CFL/LED alternatives that are less easily locally made and involve more mining, component manufacture, product assembly, and recycling when not dumped (referenced US analysis below recommending recycling also of LEDs, on toxicity grounds).
In particular, all the extra transport use of energy and emissions in each of the above stages, including dirty bunker oil fueled ships bringing products or their parts from China.
In addition, an electricity usage that not only as mentioned is small and largely off-peak and therefore electricity that is available anyway - but also which, if emission-free, may actually lead to an increase in emissions with replacement bulbs and room heating from oil or other potentially pollutant sources, as referenced with different research studies.

Note:
The traditional analyst response to light bulb life cycle issues is to say
"Well, Osram says X energy is used in making those bulbs, and that is insignificant compared to usage savings!"
Certainly:
But that is therefore just the final assembly into a bulb - ignoring all the mining, component manufacture, recycling and certainly all the life cycle transport from raw material to component to product to recycling.
These are ignored (as are heat benefit, power factor and other effects) as being hard to quantify.
But estimates can be made about them - at least they should be taken into overall consideration.

Energy used in (say) China may be irrelevant to EU savings, but not released emissions on EU climate policy.
The proposal to support EU LED industry then raises the energy life cycle factors as well.

There is no excuse to leave out such factors in overall assessment.





Regarding environmental impact, related to health:

The review study examined the available knowledge on the impact of artificial lighting on human health from scientific publications. The update on health aspects did not identify any significant negative or positive impacts from the stage 6 requirements, or from a possible ban of halogen technology, due to the availability of suitable replacement options and the inclusion of certain information requirements in EU legislation.

Stage 6 requirements effectively only allow fluorescent or LED lighting for general service household lamps.

The issues with flourescent (CFL) bulbs are well known with respect to mercury, UV radiation, light quality and other issues - and also recognized as such by health and environmental agencies, for example in clean up mandates of bulbs and in recommendations of minimal distances and/or doubly enclosed CFLs for close usage.
A particular concern is the dumping of CFLs rather than going to recycling, with the associated risks of released mercury, as highlighted in a Swedish scandal in recent years - and Sweden tends to be seen as an environmentally conscious country, similar problems are not necessarily raised for attention elsewhere!
The concerns with CFLs are extensively covered and referenced here: http://ceolas.net/#li18eax


The new focus on LEDs may be assumed to diminish some of those issues.
But toxicity, resource depletion and environmental dumping concerns would nevertheless remain, as covered here in the safety section.
Department of Chemical Engineering and Materials Science, University of California, USA concerning the toxicity of LEDs:
"Higher resource depletion and toxicity potentials than the incandescent bulb due primarily to their high aluminum, copper, gold, lead, silver, and zinc.
According to California regulations, excessive levels of copper (up to 3892 mg/kg; 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) render all except low-intensity yellow LEDs hazardous"
Because the bulbs have very different expected lifetimes, they “normalized” their data on resource depletion and toxicity potential by using data for fifty incandescents, five CFLs, and one LED bulb. Even after normalizing their calculations, the team found that CFLs have from three to 26 times higher resource depletion and toxicity potential than incandescents and LED bulbs have two to three times higher potential.
Figures are in reality higher still: incandescents can last much longer than the assumed 1000 hours, a standard arising out of the GE-Philips-Osram Phoebus cartel. LEDs 50 000 hour assumed life can similarly be questioned - it arises out of lab specifications rather than real life use, as covered here, and similarly with assuming CFLs to last 10x longer than standard incandescents.


But LEDs also have light quality concerns.
As it happens, the German Baubiologie association, on building construction, has in a recent 30th October article just warned against LED lighting on flicker grounds, not necessarily noticeable by the human eye, leading to people feeling unwell in the different ways described.

The official French health agency ANSES in 2013 again pointed out issues seemingly unadressed by the EU, relating to source glare and blue light issues, originally highlighted by them in extensive 2010 research.
Unforunately the problems particularly arise with the most common "white LED" lamp types.
Translated from the French research.. Necessary to restrict LED availability ahead of proof of not presenting a greater blue light danger than traditional forms of lighting do... necessary to adopt new norms (NF EN 62 471)... necessary to show respect for sensitive and particularly exposed individuals... necessary that norms are respected also generallly relative to comfort and visual conditions in workplaces and homes...
recommendation to reduce LED lighting usage particularly where there is glare from the luminaries used... recommendation for EU labelling to more clearly show light quality and photobiological risk according to norm NF EN 62 471
LED blue light has diverse health problems as easily seen by several other studies online.

CFLs and LEDs can hardly be made, and are rarely sold, to equivalent omnidirectional c.1380 lumen brightness of 100W incandescent bulbs, of particular issue to old people with worse eyesight.
But that is not all:
A particular issue of the greater blue light component of CFLs and LEDs is that this makes such lighting appear still dimmer to old people, since eye lenses yellow with age, absorbing such light.

The "green" light choice is, at the least, open to debate.





Regarding money savings for consumers:

No changes to legislation:
Overall monetary savings for consumers up to 2025 compared to scenario I, taking into account higher acquisition costs and lower running costs: 9 billion EUR

2 year delay to stage 6 legislation:
Overall monetary savings for consumers up to 2025 compared to scenario I, taking into account higher acquisition costs and lower running costs: 15.3 billion EU

As based on consultancy report data (MV= mains voltage):

The MV-HL lamp has 36W power (500 lm, 14 lm/W), 2000h product life and a list purchase price of € 3.
The equivalent LED lamp is expected to have 5.4 W power (500 lm, 93lm/W), 20 000 h product life and a list price of € 10.
Both are assumed to have an operating time of 500h per year and thus the MV-HL uses 18 kWh/year (€ 3.96/year in electricity at a 2016 electricity rate of € 0.22/kWh) and the LED lamp uses 2.7 kWh/year (€ 0.60/year at the same rate).

Using 2016 parameters and list prices, the expected ‘payback period’ of LED versus MV HL lamp is around 2.4 years at 500h/yr.
At an operating time of 250h per year, instead of 500h per year, the payback period would be 4.2 year

Consumer - Higher acquisition costs € 0.4 bn
- Higher running costs of LED lamps over 2026-2060: € 1.9 bn
- Longer payback period for LED vs. HL: 2.4 versus 1.4 years
- Possible functional deficiencies LED retrofit in initial period
(dimmability, CRI, lumen output, etc.)
- Lower running costs over 2016- 2025 period: € 9.4 bn

A criticism of these figures suitably has 3 sections, the data itself, other energy usage factors, and extraneous indirect factors affecting what consumers pay.

1. The data itself

Bulb Lifespan
Quoted as 2000 hrs for Halogen and 20 000 hrs for LEDs.
LED lifespans have several question marks in their lab based specifications (more - http://ceolas.net/#li15ledax), but 20 000hrs is more conservative than other common estimates by regulation supporters. As it happens it makes little difference in the overall savings perspective, as per the data: acquistion cost is a minor factor compared to running cost.

Torsten Sundmacher, Sustain Consult comment, annex to the consulatncy report:

...the service life assumption of 40 years for LED is rather unlikely...
operating hours... switch-on times... cannot translate into service life without much ado.
Opposing facts (that are admittedly not easy to measure) are impacts such as premature scrapping e.g. for reasons of fashion, diminishing brightness, colour changes in light, more efficient successor products or the combination of the LED with other technical features (such as wireless control options integrated in the base).
The aging of structural components without operation (particularly organic compounds such as adhesives or parts of electronic systems) also speaks against a service life of 40 years.
Also, the standard plastic bulbs typically used display some marked decolouration (e.g. yellowing) after a few years in practical use, which can lead to premature replacement, too.

In that case, if people switch bulbs more often, and LED energy efficiency progresses as the Kemna report also suggests, then the usage savings keep increasing anyway, stage 6 or no stage 6 (see energy comment, lock-in effect, above).
A ban on halogens obviously leaves little choice, while if LEDs get better and cheaper people will buy more of them whatever the other choices are - which of course challenges the need to ban any incandescents, not just halogens.


Bulb Usage
The consultancy figures, while not assuming a high 3 hr daily average usage per bulb (1000 hrs per annum), still come out at a rather high -roughly- 1 1/2 hrs (500 hours p.a.) or 45 mins (250 hours p.a.) daily average usage assumption per bulb.
As seen, the Commission Proposal uses the higher 500 hour per year LED lamp usage assumption.
Previous Paolo Bertoldi et alia EU Commission surveys have shown 20-25 lighting points per EU household, substantially more in Northern Europe. Usage doubtfully comes out as such high figures per bought bulb. In fairness, the most used bulbs would likely be replaced first, so there would be an initial stacking of higher average use among those
bulbs, but this would therefore soon become progressively lower, as less used bulbs become replaced, particularly on assuming legacy incandescent short lifespan stock are fitted.

There is also an assumption based on extrapolating sales figure curves which does not necessarily hold.
Replacing commonly used bulbs with LEDs has a desirable payback logic for the consumer, but this decreases more and more for less used bulbs, and resistance to purchase (and using stocked bulbs, smuggled bulbs, allowable halogens) may be expected, unless LEDs hit the 3 euro kind of level assumed for halogens.
A second reason for increasing consumer resistance is that lighting situations that don't suit LEDs would increasingly come up eg dedicated dimmer, timer, sensor circuits, old fittings, etc, and in fairness the consultancy report mentions this, along with brightness requirements that in particular the cheap LEDs would hardly match, and the Colour Rendering Index (CRI) which is maximal 100 for incandescent lighting (Aside note: hence the clamour for a new Colour Quality Scale (CQS) index that, er, shows LEDs in a better light. Ah yes).

Of course if the EU simply invokes a final solution ban of all non-LED light bulb alternatives, the problem is largely, as it were, "solved"! Screw citizens, screw citizen choice.


Electricity Price
Average prices seem to have been used. Most lighting usage is off-peak after 7pm on DEFRA-Intertek UK data, likely similar throughout the EU based on work times and evening darkness. Time-based electricity pricing is becoming more common and is favoured by utilities. While currently consumer night-pricing often has relatively late start times, the expected smart grid-smart meter developments will likely radically alter this.
Since the EU savings are projected far into the future, they should take that into account.
Conversely "energy shocks" (Germany?) might raise prices, but hardly in equivalent fashion, and overall the future in terms of varied available energy sources for electricity is assured, even with lots of green fingered interference.


Overall
The consultancy report is a lot more reasonable than others I have seen in savings projections.
That said, in the 2025 perspective they use the savings are highly questionable - and predictably questionable right now, not just because 2025 is far away.
The Commission stance is even more questionable as based on the higher 500hr yearly average bulb usage assumption.



2. Energy usage factors

Previously mentioned factors affecting energy savings obviously also affect money savings.
Hence the mentioned incandescent heat benefit and the inferior CFL/LED power factors both lower supposed switchover savings, the latter also in any costly countermeasures that utility companies may have to take (which is why industrial users are cost penalised if presenting power factor disadvantages to the grid).

Also as mentioned, the consumer reactive activities - using more dim bulbs to compensate for the lack of omnidirectional bright ones, or preferring brighter halogens (with higher electricity usage per bulb) for the same reason.
Again, the rebound effect of leaving lights on that are cheap in usage, especially fluorescent types that are slow to come on in the cold and where on-off switching reduces lifespan.




3. Extraneous factors

Government subventions with taxpayer money should be taken into account for supposed consumer savings.
As seen under financing above, the EU proposal itself goes into a few of the subventions for light bulb manufacturers to make the bulbs - and for municipal governments and others to buy them.
That means consumers paying much more than what the price tag on the bulb says - without it being acknowledged.

But again, that is not all.
Power utilities are also subvented for expected lower sales and/or they are allowed to raise prices for expected lower electricity sales arising out of consumer energy efficiency measures such as on light bulbs, as seen in UK, Germany and likely elsewhere.





Regarding Local versus China Manufacture:

LED modules are mainly produced in Asia. On the other hand, the EU is the main manufacturer of halogen lamps.
LEDs are mainly produced in Asia by companies with experience in computer chip production, because their manufacturing requires chip wafer technology and expertise similar to that used in the silicone industry. Major producers are companies like Nichia, Samsung LED, LG Innotek and Seoul Semiconductor. While Osram Opto Semiconductors was the world's third biggest supplier of LED components in revenue terms in 2011, it mostly specialises in high value LED and SSL-Laser technology used in special applications such as surgical instruments. The absence of a strong chip industry in the EU is therefore one of the major obstacles to relocating general LED production to Europe.

Halogen lamp production is mainly EU-based with a share of 72% on the European market with 234 million unit sales in 2012. Employment dependent on the current production in the EU is estimated at a maximum of 7,300 industrial jobs. With the knowledge of today, the industrial activities linked to LED replacements - imported from outside the EU - are expected to bring 500 new EU jobs.
Hence, it is estimated that a maximum of 6,800 jobs related to halogen production will eventually be lost.

These job losses will happen in any case due to the market transition to LEDs.
All stakeholders agree that abolishing the stage 6 requirements would postpone these job losses by a small number of years – it would not prevent them.

Jobs are clearly an issue.
The EU already acknowledged loss of at least 5000 EU jobs in the initial 2009 shift from simple incandescents - and that was just in the final phase, as manufacturers had already begun to adjust for assumed (and promised) legislative changes.
Simple incandescents, which comparatively also includes Halogens, are easy to make locally by new and/or small start-ups:
Firstly, in needing few component resources to thereby efficiently (note, "efficiently") make bright lighting.
Secondly, as patent-expired, generic light products without licensing requirements.
Thirdly, in environmental authorization, not handling toxic minerals or having inappropriate waste products or being subject to recycling collection mandates, which as mentioned has some imperatives with LED products.


But also the mentioned environmental issues relating to manufacture locality, local or not local:

1. Manufacture in China
Aside from any loss of EU jobs, note the less environmental conditions of production processes from mining to coal plant powered manufacture to bunker oil fueled ships to Europe, and possible return of recycled reprocessed parts.

2. Local manufacture
In this case, politicians can no longer ignore the manufacture energy use - which goes beyond the commonly quoted Osram and similarly based data which while showing 6-10x differential for CFLs over incandescents (and as per consultancy report US Dept of Energy referenced study, much more for LED manufacture) still only relate to assembly of components, largely ignoring component manufacture and certainly the other life cycle energy and emission issues already mentioned.

These job losses will happen in any case due to the market transition to LEDs.
All stakeholders agree that abolishing the stage 6 requirements would postpone these job losses by a small number of years – it would not prevent them.

As seen this reiterates the expected market transition to LEDs.



Conclusion

So to suitably conclude, returning to the stage 6 issue raised in the proposal:

A. If as suggested the market transitions to LEDs anyway  without the stage 6 requirements that ban Halogens, based on "LEDs are getting better and cheaper all the time":
Why then ban the Halogens. Presumably people buy more and more LEDs - voluntarily.
It can therefore hardly matter on any meaningful energy saving grounds, added to all the other stated referenced reasons that the savings are not there - and may for that matter give greater savings, as per point B.

B. Since all seem to agree that LEDs will also continually become more energy efficient, then whether or not there is a lock-in effect (from purchased long lifespan LEDs not getting changed), stage 6 can be abandoned also on those grounds:
1. Lock in effect is there
= early less energy efficient 2016 LEDs locked into 40 year use
2. Lock in effect is not there
= continually replaced LEDs means that ever more energy efficient LEDs are put in place.

C. In allowing Halogen lighting, there are no energy saving grounds for maintaining a ban on frosted, non-clear lamps.
Indeed, as from the research report, they are often more energy efficient than clear varieties, as well as having less point-source glare. 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.
No other jurisdiction than the EU maintains such a petty ban on non-clear lamps.



This is of course itself only a small part of why banning cheap popular safe electrical products makes no sense:
Unlike - say - usual cars, light bulbs are only indirectly related to the energy used and any associated emissions, and a predominant evening-night off-peak surplus supply use along with fractional grid demand negates any reasonable justification to ban a popular choice of artificial lighting, which people spend much of their lifetimes using.

If there is a problem - deal with the problem.





Footnote:
EU Commission = European Commission, official nomenclature.
I consider EU=Europe language as also reflected by "pro-Europe" etc usage as being a false equivalence (I am certainly pro-Europe, whatever about the EU).
Language use is an often ignored subject in influencing how people think (obviously freedom fighters v. terrorists and such politically, but environmentally also (constructional) efficiency v. (energy) efficiency, energy saving bulbs v. fluorescent bulbs, all-encompassing "climate change", CO2 pollution v. CO2 emissions etc) whether or not one agrees with the motivation for such use.