If energy needs to be saved, there are good ways to do it.
                                                               Government product regulation is not one of them

Wednesday, November 20, 2013

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


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.

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