Too much of a good thing?
GREENLIGHT ALLIANCE DAVE HOLLINGSBEE
Dave Hollingsbee of Stoane Lighting looks at the proposed changes to the Ecodesign for Energy Related Products & Energy Information regulations, breaking down how these changes could impact the lighting industry, both in the UK and beyond.
For the past two years the GreenLight Alliance has existed primarily with the mission to seek and promote the adoption of the circular economy. Our work aims to help all corners of the lighting industry to make meaningful, informed and fair decisions in the pursuit of more sustainable practices. Today we direct the Alliance’s gaze towards the rapidly progressing proposals for changes to the Ecodesign for Energy Related Products & Energy Information (Lighting Products) Regulations 2021, now including Minimum Energy Performance Standard (MEPS). Or, the draft statutory instrument’s full title: Energy Conservation. The Ecodesign for Energy-Related Products and Energy Information. (Lighting Products) (Amendment) Regulations 2023. This proposed regulation will impact those putting new product on the market in the UK. Does that affect you? Do you specify lighting for projects in the UK? Do you manufacture luminaires in the UK for the UK market? Do you manufacture outside of the UK and export into the UK? Do you manufacture lamps or light emitters destined for UK manufacturers/market? Are you a wholesaler or retailer who places lamps or luminaires on the UK market? If the answer to any of these questions is “yes” then this proposal affects you.
What is it?
Essentially, for the UK market it is a light-source efficacy minimum for all light-sources. It constitutes an amendment to Ecodesign and is a two-stage proposal: Tier 1 (coming into force 15/11/2023) 120 lm/W Tier 2 (coming into force 01/09/2027) 140 lm/W From where we sit as an industry in February 2023, that is an ambitious threshold to set by anybody’s reckoning.
Does the GLA applaud it?
The truthful answer is: “Not as it stands”. Members are still getting to grips with the impact of the minimum efficacies (the Pon Max calculation) 110 / 111
brought in with the EU Single Lighting Regulation (EU Com 2019/2020) and corresponding (largely mirroring) 2021 UK Statutory Instrument 2021/1095: “Ecodesign for Energy Related Products and Energy Information (Lighting Products) Regulations 2021”. In essence a large number of established “go-to” LED products fell below the new minimum efficacy thresholds established using the Pon Max calculation in the regulation. At the time, many were caught napping. Indeed it is arguably far too soon since the October 2021 implementation to know of the impacts and to comment informedly on prospects of another raising of the bar so soon, in the UK at least. One obvious concern is EU/UK divergence. With another set of environmentally motivated regulatory proposals to work with, it is hard to see how this is positive for UK lighting stakeholders or any global light source manufacturers. Of course, where we do see similarities between the UK and Europe is in the quest to reduce energy consumption and carbon emissions related to lighting. Noble and urgent aspirations, but at what cost to the UK lighting industry? What cost to manufacturing, distribution, specification and perhaps most importantly the end user?
What is meant by a light source?
This is a very good question, not as easy to answer as you might expect. It is important, there are a range of lm/W concession allowances for particular categories. To attempt to understand the legal definition in this context: have a read through the draft and UKSI 2021/1095. The wording is confusing in the proposed draft, proper understanding of intent and wording is crucial: on the face of it many light sources may not benefit from any allowances at all.
Concessions
There are allowances for some “light sources”, allowing that light source efficacy below the 120 lm/W threshold (as of this November) or 140 lm/W in 2027.