Update of the data provided by the analysis model developed in the course of the “Study to assess socio-economic impact of substitution of certain mercury-based lamps currently benefiting of RoHS 2 exemptions in Annex III”.
Date: 2020-05-12
Institutions: Directorate-General for Environment
Subjects: electrical engineering, electronic waste, electronics industry, hazardous waste, market supervision, marketing standard, mercury, waste recycling

Update of the data provided by the analysis 
model developed in the course of the “Study 
to assess socio-economic impact of 
substitution of certain mercury-based lamps 
currently benefiting of RoHS 2 exemptions 
in Annex III”

Performed under the study request 
No.07.0201/2019/811056/ENV.B.3 

Oeko-Institut e.V
May 2020

EUROPEAN COMMISSION 

Directorate-General for Environment
Directorate B - Circular Economy and Green Growth
Unit B3 - Waste Management and Secondary Materials
B-1049 Brussels

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Luxembourg: Publications Office of the European Union, 2020 

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Update of the data provided by the 
analysis model developed in the 
course of the “Study to assess socio-
economic impact of substitution of 
certain mercury-based lamps 
currently benefiting of RoHS 2 
exemptions in Annex III” 

Performed  under 
No.07.0201/2019/811056/ENV.B.3 

the  study 

request 

Authors 

Yifaat Baron 
Oeko-Institut e.V. 

Carl-Otto Gensch 
Oeko-Institut e.V. 

Freiburg, 08.05.2020 

Contact 
info@oeko.de 
www.oeko.de 

Head Office Freiburg 
P. O. Box 17 71 
79017 Freiburg 

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Phone +49 761 45295-0 

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Phone +49 30 405085-0 

Office Darmstadt 
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64295 Darmstadt 
Phone +49 6151 8191-0 

 
Peer-reviewed by Dr. Andreas Köhler, Oeko-Institut e.V. 

RoHS SEA Lamps – 2020 Revision 

Table of Contents 

List of Tables 

List of Abbreviations 

1 

2 

3 

4 

5 

Introduction and scope of the study 

Data used for the current review 

Revised estimated impacts for LFL T5 

Revised estimated impacts for LFL T8 

Conclusions 

List of References 

Annex I.  Variables used in VHK-Oeko-Institut Combined Model for RoHS 

4 

5 

6 

8 

12 

14 

17 

18 

19 

3 

List of Tables 

Table 2-1:  Lamp share estimates applied in the model 

Table 3-1:  Revised estimated impacts calculated for CFLni (using CLASP/SwEA data set) 

Draft final 

9 

11 

Table 4-1:  Revised estimated impacts calculated for T5 lamps (using CLASP/SwEA data set)  13 

Table 5-1:  Revised estimated impacts calculated for T8 lamps (using CLASP/SwEA data set)  16 

4 

 
 
 
RoHS SEA Lamps – 2020 Revision 

List of Abbreviations 

BAU 

CFLni 

LED 

LFL 

Business as usual scenario 

Compact fluorescent lamps without integrated ballast 

light-emitting diode 

Linear fluorescent lamps 

MELISA 

VHK (2016) Model for European LIght Sources Analysis (MELISA) 

Plug & Play 

A lamp that can be used as a “drop-in” replacement, through its insertion into a 
luminaire (plugging in, screwing in), without requiring the performance of any 
technical changes to the luminaire aimed at establishing the compatibility of 
the luminaire with the replacement lamp. 

SUB 

Substitution scenario 

T5 

T8 

Linear fluorescent lamps with a tube diameter ≥ 9 mm and ≤ 17 mm 

Linear fluorescent lamps with a tube diameter > 17 mm and ≤ 28 mm 

VHK 

Van Holsteijn en Kemna B.V. 

5 

 
 
 
 
Draft final 

1 

Introduction and scope of the study 

In July 2019, Oeko-Institut published the final report for the “Study to assess socio-economic impact 
of substitution of certain mercury based lamps currently benefiting of RoHS 2 exemptions in Annex 
III” (Baron et al. 2019) (hereafter referred to as “2019 SEA study”). This study had been contracted 
in 2017 by the European Commission as a follow up to the “Study to assess renewal requests for 29 
RoHS 2 Annex III exemptions [no. l(a to e -lighting purpose), no. l(f - special purpose), no. 2(a), no. 
2(b)(3), no. 2(b)(4), no. 3, no. 4(a), no. 4(b), no. 4(c), no. 4(e), no. 4(f), no. 5(b), no. 6(a), no. 6(b), 
no. 6(c), no. 7(a), no. 7(c) - I, no. 7(c) - II, no. 7(c) - IV, no. 8(b), no. 9, no. 15, no. 18b, no. 21, no. 
24, no. 29, no. 32, no. 34, no. 37]” carried out by the Oeko-Institut in 2016 which recommended inter 
alia a phase-out of exemptions for certain mercury-based lamps. The goal of the 2019 SEA study 
was to assess possible socioeconomic impacts related to the substitution of these mercury-based 
lamps.  

The  study  was prepared based on  data from  the  VHK  (2016)  Model for European LIght  Sources 
Analysis (MELISA), data provided by Lighting Europe in 2015, submitted as part of its applications 
for  exemption,  as  well  as  data  provided  by  Lighting  Europe  in  2017  through  direct  consultation 
related to the study. A first version of the study was submitted to the European Commission in 2017 
but underwent several corrections until final publication in 2019. In this sense, despite the study’s 
relatively recent publication in 2019, the results of the assessments contained therein are based on 
data representing the years 2013-2017.  

Particularly the data for the availability of substitutes, which has a significant impact on the costs of 
substitution, is considered outdated. This is due to the fast development and dynamic nature of the 
LED market segment. The European Commission has received new evidence from stakeholders as 
to the share of  substitutes available and has thus requested a review of the assessment results for 
a  number  of  lamp  types:  compact  fluorescent  lamps  with  non-integrated  ballast  (CFLni),  linear 
fluorescent lamps (LFL) with a tube diameter ≥ 9 mm and ≤ 17 mm (T5) and LFL with a tube diameter 
> 17 mm and ≤ 28 mm (T8).  

This  document  presents  the  results  of  a  review  of  the  2019  SEA  study as  regards  the elements 
specified below, based on new evidence as provided by the Commission. 

Related to CFLni, T5 and T8, impacts have been calculated for the period 2021-2035, as regards: 

•  Purchase costs of substitution of such lamps with LED alternatives (considers costs of lamps and 

luminaires as well as labour costs for luminaire rewiring and for luminaire replacement); 

•  Energy savings expected through substitution of such lamps with LED; 

•  The amount of mercury avoided on the market through substitution with LED; 

•  The amount of e-waste to be generated prematurely through substitution with LED. 

6 

 
 
RoHS SEA Lamps – 2020 Revision 

The following scenarios were considered: 

•  Business as usual scenario (BAU): current RoHS exemptions for CFLni, T5 and T8 remain valid, 
however it will no longer be possible to place some conventional lamp types on the market as a 
result of the application of the new Ecodesign Regulation on light sources1.  

•  Substitution  scenario  (SUB):  RoHS  exemptions  for  CFLni,  T5  and  T8  expire,  resulting  in  a 

regulatory driven phase-out of such lamps as of 2021. 

Finally, for each lamp type, the data on market availability of substitutes used in the 2019 SEA study 
were entered into the revised model for comparison. 

1 From 1 September 2021, the Ecodesign regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 
1194/2012 will be repealed and replaced by Commission Regulation (EU) 2019/2020 of 1 October 2019 
laying down ecodesign requirements for light sources and separate control gears pursuant to Directive 
2009/125/EC of the European Parliament and of the Council. With the new regulation, most traditional 
fluorescent tube lighting T8, which are common in offices, will be phased-out from September 2023 onwards. 
Likewise, most CFL with integrated ballast will not be able to fulfil the requirements set by the Regulation 
from September 2021. 

7 

 
 
                                                
Draft final 

2  Data used for the current review 

The current estimations have been calculated applying the ‘VHK-Oeko-Institut Combined Model for 
RoHS’. For assessing the impacts of possible new RoHS measures for the above mentioned three 
lamp  types,  the  ‘VHK-Oeko  Institut  Combined  Model  for  RoHS’  uses  as  reference  the  sales, 
efficiency, power, and light source price data from the ECO-scenario of the Model for European LIght 
Sources Analysis (VHK 2019), which was developed by VHK for scenario analysis in the Ecodesign 
and Energy Labelling context. Additional input for the Combined Model comes from the 2019 SEA 
study.  In  the  combined  model,  VHK  performed  the  energy  and  cost  modelling  and  Oeko-Institut 
added modelling regarding the impacts on mercury and e-waste.  

For assessments regarding mercury impacts, values specified in the 2019 SEA study(Baronetal.É, 
table 15 (for CFLni) and table 34 (for T5 and T8) as estimated average values have been used for 
revised calculations. Regarding assessments made for e-waste impacts, values used for the revised 
calculation are based on an average of best and worst case values applied in the 2019 study (Baron 
et al. 2019). In both cases, these values were at the time consulted with Lighting Europe. 

In the 2019 SEA study, assumptions were made for each lamp type as to the following aspects:  

•  the share of lamps that would be substituted with Plug & Play LED alternatives,  

•  the share of lamps to be substituted with LED alternatives requiring a rewiring or conversion of the 

luminaire, and  

•  the share of lamps the replacement of which would require a replacement of the luminaire.  

Following the market developments of the last few years, evidence as to the current shares related 
to  these  substitution  routes  in  the  market  situation  of  2020  was  submitted  to  the  European 
Commission.  The  following  estimations  (Table  2-1)  for  LFL  were  provided  to  the  European 
Commission  by  CLASP  (Scholand  2020),  based  on  a  study  performed  jointly  with  the  Swedish 
Energy Agency (Bennich, P. & Scholand, M. 2020)2 (hereafter referred to as CLASP/SwEA report), 
providing  an  overview  of  the  current  availability  of  LED  alternatives  for  the  relevant  lamp  types. 
Estimations for CFLni  (also under  Table 2-1) were provided separately  (Bass, F. & Scholand, M. 
2020)  for  the  purpose  of  this  review  and  are  based  on  the  market  study  performed  for  the 
CLASP/SwEA  report.  These  share  estimations  shall  be  referred  to  throughout  this  study  as  the 
CLASP/SwEA data set. 

For comparison, the share estimates for the availability of LED alternatives for T5, T8 and CFLni 
initially  used  in  the  2019  SEA  study  were  also  applied  to  the  model  and  shall  be  referred  to 
throughout this study as the 2019 SEA study data set. The shares applied therein are also specified 
in Table 2-1 below. 

2 For T8, CLASP also provided data based on an estimation by Seaborough, a company developing LED 
technologies, which represents the availability of LED alternatives as estimated by this company. This 
estimate was slightly higher than that of the CLASP and Swedish Energy Agency report. Due to its similarity, 
the Seaborough estimations were not used for a separate assessment. 

8 

 
 
 
 
                                                
RoHS SEA Lamps – 2020 Revision 

Table 2-1: 

Lamp share estimates applied in the model 

Lamp Type 

CLASP/ 
SwEA Plug 
& Play* 

CLASP/ 
SwEA: LED 
+ Rewiring* 

CFLni  P <12 W 

12 W ≤ P < 30 W 
30 W ≤ P < 50 W 
P ≥ 50 W 

T5 
T8 

100% 

85% 
75% 
75% 

76% 
96% 

0% 

4.5% 
7.5% 
7.5% 

0.7% 
0.45% 

CLASP/ 
SwEA: 
Luminaire 
replacement* 
0% 

10.5% 
17.5% 
17.5% 

23.3% 
3.55% 

2019 SEA 
study** 
Plug & 
Play 

0% 

20% 
0% 
0% 

1% 
12% 

2019 SEA 
study**: 
LED + 
Rewiring 
30% 

2019 SEA 
study**: 
Luminaire 
replacement 
70% 

24% 
30% 
30% 

3% 
10% 

56% 
70% 
70% 

96% 
78% 

Source: *Estimations presented for P&P by CLASP at Stakeholder meeting of 12.2.2020 and confirmed per email by Michael Scholand 
on 25.3.2020 and by (Bass, F. & Scholand, M. 2020). Estimations for LED+Rewiring and for Luminaire replacement calculated for 
remainder by Oeko-Institut. **Estimations from the 2019 SEA study are reproduced from the study for all categories.  
Note: The CLASP estimation for T8 is a combined estimation for EM/CGG (100% coverage representing 70% of the market share) and 
HF/ECC (88% coverage representing 30% of the market share);  

Detailed explanations as to how market flows and certain impacts have been calculated are specified 
in the 2019 SEA report. Additional input variables used appear  in Annex I. The following sections 
provide a summary of the results of the revision, calculated on the basis of the data sets specified 
above.Revised estimated impacts for CFLni 

The revised calculations for impacts of the regulatory driven substitution of CFLni lamps, performed 
on the basis of the CLASP/SwEA data set, are presented in Table 2-2.  

The first line in the table  presents the projected sales of CFLni, decreasing with the years, which 
would  take  place  in  the  BAU  scenario,  where  RoHS  exemptions  remain  applicable  for  CFLni. 
Practically all these sales are replacement sales, i.e., of CFLni replacing CFLni that have reached 
the  end-of-life.  In  the SUB  scenario,  once  the  RoHS exemptions are  revoked,  it  is assumed  that 
CFLni could no longer be sold and could no longer be used for replacement of such lamps at end-
of-life.  Thus,  all  such  replacements  would need  to  be  performed  with LEDs  through  Plug  & Play 
replacements, through such replacements with additional rewiring work or through replacement of 
the  luminaire.  In  the  residential  sector,  where  CFLni  lifetime  is 14  years, LED  replacements  take 
place based on these sales until 2035 (second line in table). In the non-residential sector however, 
where the average CFLni lifetime is 6 years, in the BAU scenario, CFLni sold in for example 2027 
would replace CFLni sold in 2021. In contrast, in the SUB Scenario, CFLni replaced in 2021 by LEDs, 
which have a much longer lifetime, will not need to be replaced again in 2027, nor later within the 
observed period. Therefore, from 2027 onwards, non-residential CFLni replaced by LED are set to 
zero (third line in table).   

The additional purchase costs are computed as the sum of  (additional) costs in the SUB scenario 
for  LED  Plug  &  Play,  LED  +  rewiring,  and  LED  +  luminaire  replacement,  minus  the  (avoided) 
purchase  costs for  CFLni of the  BAU  scenario. The additional  purchase  costs  decrease  with  the 
years because the number of CFLni lamps substituted by LEDs decreases and because LED prices 
progressively  decrease.  From  2027,  the  additional  costs  are  close  to  zero  because  only  few 
residential CFLni are still to be replaced by LED. 

Energy savings are computed as the difference between electricity consumption by LEDs replacing 
CFLni in the SUB scenario and electricity consumption that CFLni would otherwise have generated 
in  the  BAU  scenario.  The  difference  is  multiplied  by  the  electricity  rate  (€/kWh)  to  derive  the 

9 

 
 
 
 
Draft final 

corresponding cost savings. Energy savings (negative values in the table) increase in early years 
but later start to decrease (2027) and values even become positive (indicating additional expense) 
in the last years of the analysis period. Within the analysis, the different lifetimes for CFLni and LED 
and the decrease in sales year-by-year (lamps to be replaced) will lead to a LED stock (and energy) 
that is higher than the  CFLni stock (and energy) in later years.  This leads to the decrease in the 
energy saving costs from 2027 onwards.  

Combining the additional purchase costs with the costs regarding saved energy leads to an annual 
net benefit  already from  2024, whereas cumulatively, the total purchase costs are set-off by total 
energy  savings  starting  from  2027.  The  regulatory-driven  substitution  would  result  in  a  total  net 
benefit of 1033 million euros for the period between 2021 and 2035. Considering a total number of 
243 million CFLni substituted by LEDs, this translates into a net benefit of 4.27 euros per lamp. 

In the period between 2021 and 2035, given that alternatives do not contain mercury, a total amount 
of  856  kg  of  mercury  is  avoided  from  being  placed  on  the  EU  market.  On  the  other  side,  the 
regulatory-driven phase-out in some cases would result in the need to rewire existing luminaires or 
to  replace  them,  which  generates  a  total  amount  of  22,000  tonnes  of  e-waste  prematurely 
(accelerated  impact).  It  is  noted  that  this  calculation  does not  consider  that fluorescent  lamps or 
luminaires may weigh more than the LED lamps or luminaires replacing them, which in the long term 
could lead to a decrease in generated e-waste.

10 

 
 
RoHS SEA Lamps – 2020 Revision 

Table 2-2: 

Revised estimated impacts calculated for CFLni (using CLASP/SwEA data set) 

2021  2022  2023  2024  2025  2026  2027  2028  2029  2030  2031  2032  2033  2034  2035 

CFLni projected sales, all sectors (mln) 
CFLni replaced by LED, residential (mln) 
CFLni replaced by LED, non-resident. (mln) 

Total energy savings in SUB, GWh 
Total energy cost savings in SUB, M euros 

Avoided purchase cost in SUB for CFLni, M 
euros 
Additional purchase cost for LED in SUB 
plug&play, M euros 
Additional cost for LED+rewiring in SUB, M 
euros 
Additional cost for LED+luminaire in SUB, M 
euros 
Total additional purchase costs in SUB, M 
euros 
Total additional cost in SUB, M euros 

Cumulative from period start in SUB, M euros 

Total avoided mercury in SUB in kg  

Total additional E-waste in SUB in million kg 

44.8 
13.3 
31.4 
-693 
-124 

-208 

41.9 
13.2 
28.6 
-1354 
-245 

38.1 
12.9 
25.2 
-1966 
-359 

33.5 
12.3 
21.2 
-2506 
-463 

28.6 
10.9 
17.6 
-2974 
-555 

23.5 
9.3 
14.2 
-3363 
-634 

19.1 
7.6 
0.0 
-2712 
-521 

15.0 
5.8 
0.0 
-2068 
-405 

11.3 
4.4 
0.0 
-1459 
-294 

-195 

-179 

-158 

-135 

-111 

-91 

-71 

-54 

471 

403 

345 

285 

229 

186 

68 

62 

56 

48 

40 

33 

292 

274 

249 

219 

187 

153 

624 

544 

471 

394 

321 

261 

500 

500 

134 

4,1 

299 

800 

126 

3,8 

112 

912 

114 

3,5 

-68 

843 

101 

3,0 

-234 

609 

86 

2,6 

-373 

236 

71 

2,1 

38 

8 

50 

6 

-515 

-279 

57 

0,7 

28 

6 

38 

2 

-404 

-682 

45 

0,5 

21 

5 

29 

0 

-294 

-976 

34 

0,4 

8.3 
3.4 
0.0 
-912 
-192 

-39 

16 

4 

22 

2 

6.5 
2.8 
0.0 
-443 
-103 

-31 

13 

3 

19 

3 

5.1 
2.4 
0.0 
-56 
-29 

-24 

11 

3 

16 

5 

-191 

-99 

-24 

3.9 
2.1 
0.0 
266 
33 

-19 

9 

2 

13 

6 

39 

3.0 
1.7 
0.0 
530 
83 

-15 

8 

2 

11 

6 

2.2 
1.4 
0.0 
734 
122 

-11 

7 

2 

9 

6 

89 

128 

-1167 

-1266 

-1290 

-1251 

-1162 

-1033 

25 

0,3 

20 

0,3 

15 

0,2 

12 

0,2 

9 

0,2 

7 

0,1 

Source: Calculated with the VHK-Oeko-Institut Combined Model for RoHS; Note: Values are rounded; Negative values represent benefits 

These results change significantly when applying the 2019 SEA study data set estimate on the availability of between 0 to 20% Plug & Play 
substitutes to the calculation model. In total, the regulatory-driven substitution results for this data set in a total net cost of over 10,860 million 
euros for the period between 2021 and 2035 due to the high costs of luminaire replacements. This translates into a cost of 44.89 euros per 
lamp. 

In this period, the amount of mercury avoided on the EU market remains the same under both CLASP/SwEA and 2019 SEA data sets as the 
number of lamps to be replaced has not changed, but a larger amount of e-waste, 180 thousand tonnes, is generated prematurely (accelerated 
impact) when applying the 2019 SEA data set as a larger number of lamps replaced require rewiring (24-30%) or luminaire replacement (56-
70%).

11 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RoHS SEA Lamps – 2020 Revision 

3  Revised estimated impacts for LFL T5 

The revised calculations for impacts of the regulatory driven substitution of LFL T5 lamps, performed 
on the basis of the CLASP/SwEA data set,  are presented in Table 3-1.  

The first line in the table presents the projected sales of LFL T5, decreasing with the years, which 
would take place in the BAU scenario, where RoHS exemptions remain applicable for such lamps. 
Most of these sales are replacement sales, i.e. LFL T5 replacing LFL T5 that have reached end-of-
life. In the SUB scenario, once the RoHS exemptions are revoked, it is assumed that LFL T5 could 
no longer be sold and could no longer be used for replacement of such lamps at end-of-life. Thus, 
all such replacements would need to be performed with LEDs through Plug & Play replacements, 
through such replacements with additional rewiring work or through replacement of the luminaire. In 
the residential sector, where LFL T5 lifetime is 28 years, LED replacements  take place based on 
these sales until 2035 (second line in table). However, in the non-residential sector, where average 
LFL  T5  lifetime  is  10  years,  in  the  BAU  scenario,  LFL  T5  sold  in  for  example  2031  would  be 
replacements for LFL T5 sold in 2021. Whereas in the SUB Scenario, LFL T5s replaced by LEDs in 
2021, which have a longer lifetime,  no longer need to be replaced again in  2031. Therefore from 
2031 onwards, non-residential LFL T5 replaced by LED are set to zero (third line in table).   

The additional purchase costs are computed as the sum of (additional) costs in the SUB scenario 
for  LED  Plug  &  Play,  LED  +  rewiring,  and  LED  +  luminaire  replacement,  minus  the  (avoided) 
purchase costs for LFL T5 of the BAU scenario. The additional purchase costs decrease with the 
years  because  the  number  of  LFL  T5  substituted  by  LEDs  decreases  and  because  LED  prices 
progressively decrease.  From  2031,  the additional  costs are even negative because the avoided 
costs for LFL T5 are higher than the additional costs for the few residential LFL T5 that are still to be 
replaced by LED. 

Energy  savings  are  computed  as  the  difference  between  electricity  consumption  by  LEDs 
substituting LFL T5 in the SUB scenario and electricity consumption that LFL T5 would otherwise 
have had in the BAU scenario. The difference is multiplied by the electricity rate (€/kWh) to get the 
corresponding cost savings. Energy savings (negative values in the table) increase in early years 
but later start to decrease. The different lifetimes for LFL T5 and LED and the decrease in sales from 
year to year (lamps to be replaced) lead to a LED stock (and energy) that is higher than the LFL T5 
stock (and energy) in later years. This leads to the decrease in the energy saving costs from 2031 
onwards.  

Combining the additional purchase costs with the saved energy costs leads to an annual net benefit 
already from  2026,  whereas cumulatively  the  total  purchase costs  are  set-off  by  the total energy 
savings starting from 2031. The regulatory-driven substitution results in a total net benefit of 5836 
million  euros  for  the  period  between  2021  and  2035.  Considering  a  total  of  430  million  LFL  T5 
substituted by LEDs, this translates into a net benefit of 13.59 € per lamp. 

In the period between 2021 and 2035, a total amount of 1064 kg of mercury is avoided from being 
placed on the EU market. On the other side, the regulatory driven phase-out leads in some cases to 
the need to rewire existing luminaires or to replace them, which generates a total amount of 156,000 
tonnes of e-waste prematurely (accelerated impact). It is noted that this calculation does not consider 
that fluorescent lamps or luminaires may weigh more than the LED lamps or luminaires replacing 
them, which in the long term could lead to a decrease in generated e-waste. 

12 

 
 
RoHS SEA Lamps – 2020 Revision 

Table 3-1: 

Revised estimated impacts calculated for T5 lamps (using CLASP/SwEA data set) 

LFL T5 projected sales, all sectors (mln) 
LFL T5 replaced by LED, residential (mln) 
LFL T5 replaced by LED, non-resid. (mln) 

Total energy savings in SUB, GWh 
Total energy cost savings in SUB, M euros 
Avoided purchase cost for LFLT5 in SUB, M 
euros 
Additional purchase cost for LED plug&play in 
SUB, M euros 
Additional cost for LED+rewiring in SUB, M 
euros 
Additional cost for LED+luminaire in SUB, M 
euros 
Total additional purchase costs in SUB, M 
euros 
Total additional cost in SUB, M euros 
Cumulative from period start in SUB, M euros 

Total avoided mercury in SUB, in kg 

Total additional E-waste in SUB, in million kg 

2021  2022  2023  2024  2025  2026  2027  2028  2029  2030  2031  2032  2033  2034  2035 

61.2 
0.4 
60.8 
-1477 
-260 
-485 

57.3 
0.3 
56.9 
-2984 
-531 
-454 

52.7 
0.3 
52.3 
-4501 
-808 
-418 

47.7 
0.3 
47.4 
-5980 
-1085 
-378 

42.7 
0.3 
42.5 
-7389 
-1354 
-339 

39.3 
0.3 
39.1 
-8754 
-1620 
-312 

36.1 
0.2 
35.9 
-10033 
-1875 
-286 

33.0 
0.2 
32.8 
-11223 
-2118 
-262 

29.9 
0.2 
29.7 
-12321 
-2349 
-237 

26.8 
0.2 
26.6 
-13321 
-2565 
-213 

25.0 
0.3 
0.0 
-10885 
-2096 
-199 

1430 

1218 

1056 

908 

767 

701 

616 

541 

482 

424 

23 

20 

18 

16 

14 

12 

11 

10 

9 

8 

1566 

1467 

1348 

1221 

1094 

1007 

924 

845 

766 

687 

4 

0 

8 

23.1 
0.4 
0.0 
-8572 
-1651 
-184 

6 

0 

21.1 
0.6 
0.0 
-6427 
-1238 
-168 

7 

0 

19.0 
0.7 
0.0 
-4467 
-861 
-151 

9 

0 

11 

15 

17 

16.9 
0.8 
0.0 
-2694 
-520 
-135 

10 

0 

20 

2533 

2250 

2004 

1767 

1536 

1408 

1265 

1134 

1019 

906 

-186 

-167 

-146 

-125 

-105 

2273 

2273 

122 

22,2 

1720 

3993 

115 

20,8 

1196 

5189 

105 

19,1 

682 

182 

-211 

-610 

-984 

-1329 

-1659 

-2282 

-1818 

-1384 

-986 

-625 

5871 

6053 

5842 

5232 

4247 

2918 

1259 

-1023 

-2841 

-4225 

-5211 

-5836 

95 

85 

79 

72 

66 

60 

17,3 

15,5 

14,3 

13,1 

12,0 

10,9 

54 

9,7 

50 

0,1 

46 

0,2 

42 

0,2 

38 

0,2 

34 

0,3 

Source: Calculated with the VHK-Oeko-Institut Combined Model for RoHS; Note: Values are rounded; Negative values represent benefits 

These results change significantly when applying the 2019 SEA study data set on the availability of 1% Plug & Play substitutes to the calculation 
model. In total, the regulatory-driven substitution results for this data set in a total net cost of over 20,895 million euros for the period between 
2021 and 2035 due to the high costs of luminaire replacements. This translates into a cost of 48.65 euros per lamp. 

In this period, the amount of mercury avoided on the EU market remains the same under both the CLASP/SwEA and 2019 SEA data sets as the 
number of lamps to be replaced has not changed, but a larger amount of e-waste, 643 thousand tonnes, is generated prematurely (accelerated 
impact) when applying the 2019 SEA data set as a larger number of lamps replaced require rewiring (3%) or luminaire replacement (96%).

13 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RoHS SEA Lamps – 2020 Revision 

4  Revised estimated impacts for LFL T8  

The revised calculations for impacts of the regulatory driven substitution of LFL T8 lamps, performed 
on the basis of the CLASP/SwEA data set,  are presented in Table 4-1.  

The first line in the table presents the projected sales of LFL T8, decreasing with the years, which 
would  take  place  in  the  BAU  scenario,  where  RoHS  exemptions  remain  valid  for  LFL  T8.  This 
projection  reflects  the  Ecodesign  scenario  with  phase-out  of  most  LFL  T8  for  energy  efficiency 
reasons starting from 2023. Most of these sales are replacement sales, i.e. LFL T8 replacing LFL T8 
that have reached end-of-life. In the SUB scenario, once the RoHS exemptions are revoked, it is 
assumed that LFL T8 could no longer be sold and could no longer be used for replacement of such 
lamps at end-of-life. Thus, all such replacements would need to be performed with LEDs through 
Plug  &  Play  replacements,  through  such  replacements  with  additional  rewiring  work  or  through 
replacement  of  the  luminaire.  In  the  residential  sector,  where  LFL  T8  lifetime  is  18  years,  LED 
replacements take place based on these sales until 2035 (second line in table). However, in the non-
residential sector, where average LFL T8 lifetime is 10 years, LFL T8 sold in for example 2031 in the 
BAU scenario would be replacements for LFL T8 sold in 2021. Whereas in the SUB scenario, LFL 
T8 replaced in 2021 by LEDs, which have a longer lifetime,  will not need to be replaced again in 
2031. Therefore from 2031 onwards, non-residential LFL T8 replaced by LED are set to zero (third 
line in table).   

The additional purchase costs are computed as the sum of (additional) costs in the SUB scenario 
for  LED  Plug  &  Play,  LED  +  rewiring,  and  LED  +  luminaire  replacement,  minus  the  (avoided) 
purchase costs for LFL T8 of the BAU scenario. The additional purchase costs decrease with the 
years  because  the  number  of  LFL  T8  substituted  by  LEDs  decreases  and  because  LED  prices 
progressively  decrease.  From  2031,  the  additional  costs  are  even  slightly  negative  because  the 
avoided costs for LFL T8 are higher than the additional costs for the few residential LFL T8 that are 
still to be replaced by LED. 

Energy  savings  are  computed  as  the  difference  between  electricity  consumption  by  LEDs 
substituting LFL T8 in the SUB scenario and electricity consumption that LFL T8 would otherwise 
have had in the BAU scenario. The difference is multiplied by the electricity rate (€/kWh) to get the 
corresponding cost savings. Energy savings (negative values in the table) increase in early years 
but later start to decrease and values even become positive (indicating additional expense) in the 
last years of the analysis period. The different lifetimes for  LFL T8 and LED and the decrease in 
sales from year to year (lamps to be replaced) lead to a LED stock (and energy) that is higher than 
the LFL T8 stock (and energy) in later years.  

Combining the additional purchase costs with the saved energy costs leads to an annual net benefit 
already  in  2023,  whereas  the  cumulative  total  purchase  costs  are  set-off  by  the  cumulative  total 
energy savings starting from 2026. As of 2032, the annual net benefit for energy savings is negative 
(i.e. costs occur), however, this is due to the number of LFL to be replaced in these years having 
significantly decreased. Thus, in the comparison of energy consumption, the total consumption of 
LEDs operating in this period is larger than that of still operating LFL, resulting in energy costs rather 
than savings. Nonetheless, the total cumulative costs show a net benefit until the end of the observed 
period. In total, the regulatory driven substitution results in a total net benefit of  over 6593 million 
euros for the period between 2021 and 2023. Considering a total of 372 million LFL T8 substituted 
by LEDs, this translates into a net benefit per lamp of 17.70 euros. 

14 

 
 
RoHS SEA Lamps – 2020 Revision 

In the period between 2021 and 2035, a total amount of 962 kg of mercury is avoided from being 
placed on the EU market. On the other side, the regulatory driven phase-out leads in some cases to 
the need to rewire existing luminaires or to replace them, which generates a total amount of 32,000 
tonnes of e-waste prematurely (accelerated impact). It is noted that this calculation does not consider 
that fluorescent lamps or luminaires may weigh more than the LED lamps or luminaires replacing 
them, which in the long term could lead to a decrease in generated e-waste.

15 

 
 
RoHS SEA Lamps – 2020 Revision 

Table 4-1: 

Revised estimated impacts calculated for T8 lamps (using CLASP/SwEA data set) 

LFL T8 projected sales in SUB, all sectors (mln) 
LFL T8 replaced by LED in SUB, residential (mln) 
LFL T8 replaced by LED in SUB, non-resid. (mln) 
Total energy savings in SUB, GWh 

Total energy cost savings in SUB, M euros 
Avoided purchase cost for LFLT8 in SUB, M 
euros 
Additional purchase cost for LED plug&play in 
SUB, M euros 
Additional cost for LED+rewiring in SUB, M 
euros 
Additional cost for LED+luminaire in SUB, M 
euros 
Total additional purchase costs in SUB, M euros 

2021  2022  2023  2024  2025  2026  2027  2028  2029  2030  2031  2032  2033  2034  2035 

123.9 
10.2 
113.7 
-4645 

99.9 
7.1 
92.8 
-8695 

-820 
-1060 

-1550 
-854 

60.7 
3.9 
56.8 
-
11355 
-2045 
-518 

28.4 
1.9 
26.5 
-
12674 
-2305 
-242 

17.8 
1.2 
16.5 
-
13539 
-2487 
-152 

12.5 
0.9 
11.5 
-
14171 
-2629 
-106 

7.8 
0.6 
7.2 
-
14571 
-2730 
-67 

7.0 
0.7 
6.3 
-
14931 
-2826 
-60 

6.2 
0.7 
5.4 
-
15246 
-2915 
-53 

5.2 
0.7 
4.5 
-
15511 
-2995 
-45 

4.4 
0.7 
0.0 
-5026 

-977 
-38 

3.7 
0.6 
0.0 
3537 

3.0 
0.6 
0.0 

2.3 
0.6 
0.0 
8727  11084 

1.8 
0.5 
0.0 
12534 

671 
-32 

1669 
-26 

2123 
-21 

2402 
-16 

4509 

3338 

1923 

855 

504 

351 

210 

180 

154 

127 

12 

11 

11 

10 

34 

26 

15 

7 

604 

487 

296 

138 

4 

87 

3 

61 

2 

38 

2 

34 

1 

30 

1 

25 

0 

3 

0 

3 

0 

3 

4087 

2998 

1716 

758 

443 

308 

183 

156 

132 

108 

-23 

-18 

-12 

0 

3 

-8 

9 

0 

3 

-5 

Total additional cost in SUB, M euros 
Cumulative from period start in SUB, M euros 

3267 

3267 

1448 

4714 

4386 

2838 

794 

-1527 

-4074 

-6745 

-9527 

-329 

-1547 

-2044 

-2321 

-2547 

-2670 

-2782 

-2887 

-1001 

653 

1657 

2115 

2397 

Total avoided mercury in SUB, in kg 

Total additional E-waste in SUB, in million kg 

310 

10,6 

250 

8,6 

152 

5,2 

71 

2,4 

44 

1,5 

31 

1,1 

20 

0,7 

18 

0,6 

15 

0,5 

Source: Calculated with the VHK-Oeko-Institut Combined Model for RoHS; Note: Values are rounded; Negative values represent benefits 

-
12414 
13 

-
13415 
11 

-
12762 
9 

-
11105 
7 

0,4 

0,1 

0,1 

0,1 

-8990 

-6593 

6 

0,0 

4 

0,0 

These results change significantly when applying the 2019 SEA study data set on the availability of 12% Plug & Play substitutes to the calculation 
model. In total, the regulatory-driven substitution results in a total net cost of over 22,868 million euros for the period between 2021 and 2035 due 
to the high costs of luminaire replacements. This translates into a cost of 61.41 euros per lamp. 

In this period, the amount of mercury avoided on the EU market remains the same under both the CLASP/SwEA and 2019 SEA data sets as the 
number of lamps to be replaced has not changed, but a larger amount of e-waste, 703 thousand tonnes, is generated prematurely (accelerated 
impact) applying the 2019 SEA data set as a larger number of lamps replaced require rewiring (10%) or luminaire replacement (78%). 

16 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
RoHS SEA Lamps – 2020 Revision 

5  Conclusions 

For all lamp types (CFLni, LFL T5 and LFL T8), the total costs of not granting the exemption renewals 
requested (a substitution scenario) largely depend on the share of  plug & play lamps available as 
replacements on the market at the time from when the exemptions expire. This is related to the costs 
of the rewiring and, in particular, the luminaire replacement routes being much higher for the end-
user  than  a  simple  replacement  of  the  lamp.  Where  plug  &  play  alternatives  are  available,  this 
relatively quickly leads to benefits through related energy savings and enables an average benefit 
of the substitution per lamp. Where such alternatives are lacking, the costs are driven high, as a 
result of the additional labour costs for rewiring and luminaire replacement and, particularly, of the 
luminaire replacement costs for which relatively high  unit costs have been assumed in this study 
(100 euro per CFLni luminaire and 250 euro per LFL luminaire).  

Both data sets examined here, one using estimations from CLAP/SwEA and the other from the 2019 
SEA study, differ considerably in the estimations of the share of available plug & play lamps, as the 
market availability of these lamps increased significantly in the past three years.  In consequence, 
there are considerable differences in the expected costs and benefits between the results generated 
by the calculation model of these data sets. 

In relation to CFLni lamps, applying the CLASP/SwEA data set results in a total net benefit in the 
order of 1033 million euros for the period between 2021 and 2035 (benefit of 4.27 euros per lamp). 
The 2019 SEA study data set results in total costs in the order of 10,860 million euros (cost of 44.89 
euro per lamp). The process of substitution is accompanied with a premature generation of e-waste 
from  rewiring  and  lamp  replacement  of  between  22  and  180  thousand  tonnes  of  e-waste 
(CLASP/SwEA and 2019  SEA  study  respectively),  though  it  is  possible that  lower  weight of  LED 
luminaires will in the long run generate a general decrease in e-waste amounts. Both cases avoid 
856 kg of mercury being placed on the EU market. 

In relation to LFL T5 lamps, applying the CLASP/SwEA data set results in a total net benefit in the 
order of 5836 million euros to be incurred between 2021 and 2035 (benefit of 13.59 euros per lamp). 
The 2019 SEA study data set results in total costs in the order of 20,895 million euros (costs of 48.65 
euro per lamp). The process of substitution is accompanied with a premature generation of e-waste 
of  between  156  and  643  thousand  tonnes  (CLASP/SwEA  and  2019  SEA  study  respectively), 
possibly to be set-off in the future in light of lower weight of LED luminaires and tubes which could 
decrease general e-waste amounts. Both cases avoid 1064 kg of mercury being placed on the EU 
market. 

In relation to LFL T8 lamps, the CLASP/SwEA data set results in a total net benefit in the order of 
6593 million euros between 2021 and 2035 (benefit of 17.70 euros per lamp). The 2019 SEA study 
data set results in total costs in the order of 22,868 million euros (costs of 61.41 euro per lamp). The 
substitution  is  accompanied  with  a  premature  generation  of  e-waste  from  rewiring  and  lamp 
replacement  of  between  32  and  703  thousand  tonnes  of  e-waste  (CLASP/SwEA  and  2019  SEA 
study respectively), though possibly also with a general decrease in e-waste amounts in light of lower 
weight of LED luminaires and tubes. Both cases avoid 962 kg of mercury being placed on the EU 
market. 

17 

 
 
 
 
RoHS SEA Lamps – 2020 Revision 

List of References 

Literaturverzeichnis 

Baron, Y.; Blepp, M.; Gensch, C-O. (2019): Study to assess socio-economic impact of substitution 
of certain mercury-based lamps currently benefitting of RoHS 2 exemptions in Annex III. Under the 
Framework Contract led by Oeko-Institut: Assistance to the Commission on technical, socio-
economic and cost-benefit assessments related to the implementation and further development of 
EU waste legislation. Prepared for the European Commission. Unter Mitarbeit von O. Deubzer. Hg. 
v. Oeko-Institut e.V. 

Bass, F. & Scholand, M. (2020): Plug & Play CFLni, 11.02.2020. Email an Yifaat Baron. 

Bennich, P. & Scholand, M. (2020): Assessing Annex III Fluorescent Lamp Exemptions in the Light 
of Scientific and Technical Progress. Report to the Committee on the Regulation of Hazardous 
Substances. Hg. v. Swedish Energy Agency and CLASP Europe. 24.2.2020. 

Scholand, M. (2020): SEA Background document LED Linear tube compatibility table - T5 and T8 
lamps - final. Hg. v. CLASP Europe. 

VHK (2016): Model for European Light Sources Analysis (MELISA) v3, prepared for the European 
Commission, 13.07.2016. 

VHK (2019): Model for European Light Sources Analysis (MELISA). Update of 7/11/2019,. 
prepared for the European Commision. 

18 

 
 
RoHS SEA Lamps – 2020 Revision 

Annex I. 

Variables used in VHK-Oeko-Institut Combined Model for RoHS 

General input parameters 

Prices / costs 

Working hours per day 

Working days per year 

Labour cost (€/hour) 

VAT for residential users 

Electricity rate (exemplary), residential (2015 
€/kWh) (incl. VAT) 

Electricity rate, non-residential - tertiary (2015 
€/kWh) 

N lamps per luminaire 

Hours rewiring per luminaire 

Hours installation per luminaire 

2015 euros 

8 

220 

50 

20% 

2030 

0,23 

0,19 

CFLni 

all 

1,5 

0,5 

0,5 

2020 

0,21 

0,17 

2025 

0,22 

0,18 

LFL T8 

LFL T5 

2 

0,5 

0,5 

2,5 

0,5 

0,5 

FL unit price (excl. VAT, excl. install) (€) 

8,42 

7,92 

4,39 

LED light source unit price (excl. VAT, excl. 
install) (€) 

CG unit price per light source, residential, incl. 
VAT (€) 

CG unit price per light source, non-residential, 
excl. VAT (€) 

LED luminaire price, residential, incl. light source 
and CG, incl. VAT (€) 

LED luminaire price, non-residential, incl. light 
source and CG, excl. VAT (€) 

Luminous flux, residential (lm) (FL and LED) 

Luminous flux, non-residential (lm) (FL and LED) 

Annual burning hours, residential (h/a) (FL and 
LED) 

Annual burning hours, non-residential (h/a) (FL 
and LED) 

10 

10 

250 

250 

2400 

3320 

700 

2200 

Varies with year 

10 

10 

250 

250 

2275 

2600 

700 

2200 

10 

20 

100 

100 

690 

1200 

700 

1600 

Efficacy FL incl. CG, residential (lm/W) 

72 

82 

55 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
Draft final 

General input parameters 

Efficacy FL incl. CG, non-residential (lm/W) 

Power FL incl. CG, residential (W) 

Power FL incl. CG, non-residential (W) 

Efficacy LED incl. CG, residential (lm/W) 

Efficacy LED incl. CG, non-residential (lm/W) 

Power LED incl. CG, residential (W) 

Power LED incl. CG, non-residential (W) 

77 

33 

43 

85 

28 

31 

55 

12 

22 

varies with year 

varies with year 

varies with year 

varies with year 

20 

 
 
 
 
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