Source: EURLEX
Language: en
Format: md

Table of contents

Table of contents1

1.Introduction: Political and legal context2

1.1.Benefits of Ecodesign and Energy Labelling3

1.2.Legal framework4

1.3.Legal context of the reviews6

1.4.Political Context7

1.5.Need to act7

2.Problem definition8

2.1.Problem 1: Outdated energy efficiency requirements9

2.2.Problem 2: Burdensome implementation and surveillance11

2.3.Problem 3: Limited energy savings and circular economy potential from non-dismountable products12

2.4.General market failures14

2.5.Who is affected by the problems?14

3.Why should the EU act?16

3.1.Legal basis16

3.2.Subsidiarity: Necessity of EU action17

3.3.Subsidiarity: Added value of EU action17

4.Objectives: What is to be achieved?17

4.1.General objectives17

4.2.Specific objectives18

5.What are the available policy options?18

5.1.What is the baseline from which options are assessed?20

5.2.Description of the policy options20

5.3.Options discarded at an early stage27

6.What are the impacts of the policy options?29

6.1.Methodological considerations and key assumptions29

6.2.Environmental impact31

6.3.Business impacts35

6.4.Consumer expenditure37

6.5.Administrative burden39

6.6.Social Impact40

7.How do the options compare?43

7.1.Summary of the impacts43

7.2.Market Surveillance44

7.3.Assessment in view of Article 15(5) of the Ecodesign Framework Directive and Article 16 (2) of the Energy Labelling Regulation45

7.4.Assessment in view of the objectives45

8.Preferred option46

8.1.Preferred option – Why?46

8.2.REFIT (simplification and improved efficiency)47

9.How will actual impacts be monitored and evaluated?48

Annex 1: Procedural information49

Annex 2: Stakeholder consultation55

Annex 3: Who is affected and how?62

Annex 4: Analytical methods68

Annex 5: Minutes of the Ecodesign Consultation Forum123

Annex 6: Employment and Market in the lighting sector140

Annex 7: The Ecodesign and Energy Labelling Framework153

Annex 8: Existing Policies, Legislation and Standards affecting lighting products158

Annex 9: Evaluation of the Ecodesign and Energy Labelling Regulations for lighting products162

Annex 10: Energy efficiency formula179

Annex 11: Exemptions in Ecodesign185

Annex 12: Glossary199

This report commits only the Commission’s services involved in its preparation and does not prejudge the final form of any decision to be taken by the Commission.

1.Introduction: Political and legal context

The present impact assessment relates to the review of:

®Commission Regulation (EC) No 244/2009 on ecodesign requirements
[1](#footnote1)
 for lighting products applicable to non-directional household lamps,

®Commission Regulation (EC) No 245/2009 on ecodesign requirements for lighting products applicable to fluorescent lamps without integrated ballast, high intensity discharge lamps and ballasts and luminaires able to operate such lamps,

®Commission Regulation (EU) No 1194/2012 on ecodesign requirements for lighting products applicable to directional lamps, Light Emitting Diode (LED) lamps and related equipment
[2](#footnote2)
, and

®Commission Delegated Regulation (EU) No 874/2012
[3](#footnote3)
 on energy labelling for lighting products applicable to electric lamps and luminaires.

In concreto, the four current Regulations apply to:

−‘light sources’ (including lamps, bulbs, LED modules): electrically operated products that emit light using incandescence (GLS and halogens), fluorescence, high-intensity discharge, light emitting diodes (LEDs) technology – see Figure 1;

−‘control gears’ (including ballasts, electronic components, drivers): the devices needed to connect light sources to the electrical mains
[4](#footnote4)
 - see Figure 1;

−‘luminaires’: equipment which distributes, filters or transforms the light transmitted from one or more light sources and which includes all the parts necessary for supporting, fixing and protecting the light sources and, where necessary, circuit auxiliaries together with means for connecting them to the electric supply. Luminaires include wall-mounted, ceiling, table or standing luminaires. 

For the purposes of this impact assessment, "lighting products" are thus light sources, control gears and luminaires. When the control gear is integrated in the light source, the combined product is a light source.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48002.jpg)

Figure 1: Lighting technologies
[5](#footnote5)
 (above) and example of a control gear for linear fluorescent lamps (below)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48003.jpg)

1.1.Benefits of Ecodesign and Energy Labelling

Ecodesign and energy labelling are recognised globally as one of the most effective policy tools in the area of energy efficiency
[6](#footnote6)
. They are central to making Europe more energy efficient, contributing in particular to the ‘Energy Union Framework Strategy’
[7](#footnote7)
, and to the priority of a ‘Deeper and fairer internal market with a strengthened industrial base’
[8](#footnote8)
. Firstly, this legislative framework pushes industry to improve the energy efficiency of products and removes the worst-performing ones from the market. Secondly, it helps consumers and companies to reduce their energy bills. In the industrial and services sectors, this results in support to competitiveness and innovation. Thirdly, it ensures that manufacturers and importers responsible for placing products on the European Union (EU) market only have to comply with a single EU-wide set of rules.

It is estimated that by 2020, ecodesign and energy labelling regulations will deliver around 175 Mtoe (i.e. about 2035 TWh) of energy savings per year in primary energy in comparison to if there were no measures in place. This is roughly equivalent to Italy's energy consumption in 2010, close to half the EU 20 % energy efficiency target by 2020 and about 11 % of the expected EU primary energy consumption in 2020
[9](#footnote9)
.

The average household will invest in more expensive and efficient products, but in return saves about EUR 500 annually on its energy bills by 2020. Although the cost for industry, service and wholesale and retail sectors will increase, it will result in EUR 55 billion per year of extra revenue by 2020.

This legislative framework benefits from broad support from European industries, consumers, environmental non-governmental organisations (NGOs) and Member States (MSs), because of its positive effects on innovation, increased information for consumers and lower costs, as well as environmental benefits.

In the EU, lighting products have been subject to Ecodesign requirements since 2009 and Energy labelling since 2012. Electricity consumption in the EU in 2015 would have been 41 TWh higher without the existing legislation
[10](#footnote10)
. Light sources in particular are one of the largest electricity consumers worldwide and are subject to minimum energy efficiency and labelling requirements around the globe
[11](#footnote11)
.

1.2.Legal framework

In the EU, the Ecodesign Framework Directive
[12](#footnote12)
 sets a framework requiring manufacturers of energy-related products to improve the environmental performance of their products by meeting minimum energy efficiency requirements, as well as other environmental criteria such as water consumption, emission levels or minimum durability of certain components before they can place their products on the market.

The Energy Labelling Framework Regulation
[13](#footnote13)
 complements the Ecodesign Framework Directive by enabling end-consumers to identify the better-performing energy-related products, via an A-G/green-to-red scale. The Regulation sets out the general rules for rescaling the existing A+ to A+++ labels:

·Class A shall be empty at the moment of introduction of the label, and the estimated time within which a majority of the models falls into that class is at least 10 years;

·Where technology is expected to develop more rapidly, classes A and B shall be empty when introducing the label;

·Moreover, the A to G steps of the classification shall correspond to significant energy and cost savings and appropriate product differentiation from the customer’s perspective.

In general, the boundaries of the label scale are defined by the performance of products on the market incorporating ‘Best Available Technology’ (BAT) and the minimum requirement under ecodesign for those products. Subsequently, the bandwidth of the classes is determined so as to keep the same effort to move from one class to the next one. For specific product groups this may however be different to take into account appropriate product differentiation.

The BAT is determined following the MEErP methodology, and is based on purely technical grounds, i.e. the product on the market with the lowest environmental impact, while ensuring that other functional requirements (e.g. performance, quality, durability) are equivalent to the base case.

The energy label is recognised and used by 85% of Europeans
[14](#footnote14)
.

The legislative framework builds upon the combined effect of the two aforementioned pieces of legislation. See Figure 2 for a visualisation of this effect.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48004.jpg)

Figure 2: Synergetic effect Ecodesign and energy labelling

For those consumers that do not use the energy label to select a product and for consumers in a tenant-landlord situation (where the landlord set the lighting equipment and the tenant pays the bill), ecodesign requirements are important, as it safeguards consumers from the worst performing products.

The Ecodesign framework Directive and the Energy Labelling framework Regulation are implemented through product-specific implementing and delegated regulations. To be covered, the energy-related products must (i) represent a significant volume of sales (more than 200000 units a year), (ii) have a significant environmental impact within the EU and (iii) represent a significant energy improvement potential without increasing the cost excessively, see also Article 15.2 of the Ecodesign Framework Directive.

As an alternative to the mandatory ecodesign requirements, voluntary agreements or other self-regulation measures can be presented by the industry, see also Article 17 of the Ecodesign Framework Directive. If certain criteria are met the Commission formally recognises these voluntary agreements
[15](#footnote15)
. The benefits are a quicker and more cost-effective implementation, which can be more flexible and easier to adapt to technological developments and market sensitivities

For more details about the legal framework, including a full list of ecodesign and energy labelling measures, see Annex 7.

Under this framework, as listed in Section 1, lighting products are regulated by Commission Ecodesign Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012 and Commission Delegated Energy Labelling Regulation (EU) No 874/2012.

An overview of existing policies, legislation and standards affecting lighting products in the EU and outside is given in Annex 8.

1.3.Legal context of the reviews

The Ecodesign and Energy Labelling Regulations for lighting products require all the regulations to be reviewed in the light of technological progress no later than five years (three years for the 2012 acts) after their entry into force. The review of the energy labelling act should in particular assess the verification tolerances
[16](#footnote16)
.

The Ecodesign working plan 2016-2019
[17](#footnote17)
 mentions the review of the four lighting regulations as one of the major energy savings opportunities, with anticipated primary energy savings of 125 TWh per year in 2030. The working plan also requires examining how aspects relevant to the circular economy can be assessed and taken on board, in line with the Circular Economy Initiative
[18](#footnote18)
.

Finally, in August 2017, the new Energy Labelling framework Regulation (EU) 2017/1369 entered into force, repealing Directive 2010/30/EU
[19](#footnote19)
. Under the repealed Directive, energy labels were allowed to include A+ to A+++ classes to address the overpopulation of the top classes. Over time, due to technological development, also the A+ to A+++ class became overpopulated, thereby reducing the effectiveness of the labels significantly. To resolve this, the new framework regulation requires a rescaling of existing energy labels, back to the original A to G scale. Article 11 of the Energy Labelling framework Regulation lists 5 priority product groups for which new delegated acts with rescaled energy labels must be adopted at the latest on 2 November 2018. Lighting products are one of the priority product groups.

1.4.Political Context

Several new policy initiatives indicate that ecodesign and energy labelling policies are relevant in a broader political context. The main ones are the Energy Union Framework Strategy, which calls for a sustainable, low-carbon and climate-friendly economy, the Paris Agreement
[20](#footnote20)
, which calls for a renewed effort in carbon emission abatement, the Gothenburg Protocol
[21](#footnote21)
, which aims at controlling air pollution, the Circular Economy Initiative
[22](#footnote22)
, which amongst others stresses the need to include reparability, recyclability and durability in ecodesign, the Emissions Trading Scheme (ETS)
[23](#footnote23)
, aiming at cost-effective greenhouse gas (GHG) emissions reductions and indirectly affected by the energy consumption of the electricity-using products in the scope of ecodesign and energy labelling policies, and the Energy Security Strategy
[24](#footnote24)
, which sets out a strategy to ensure a stable and abundant supply of energy.

1.5.Need to act 

The need to act is driven by the following main considerations:

Cost effective energy savings:

Manufacturers and consumers stand to benefit from the fact that there are still cost effective energy savings to be achieved in the lighting sector. By way of illustration, electricity savings due to the existing requirements on lighting products were expected to be 110 TWh in 2020, but according to the last estimation will be limited to 70 TWh
[25](#footnote25)
.

Other policies/political imperatives:

Several other policies and political priorities require the revisions to look beyond the technical revisions mentioned in the review article of the existing regulations, e.g.:

·renewed effort in carbon emission abatement through the Paris climate agreement;

·the Commission’s Circular Economy policy;

·the Better Regulation policy aiming at more efficient and effective legislation;

·the need to address possible circumvention of testing standards;

·renewed energy efficiency targets..

Rescaling of energy labels

The new Energy Labelling framework Regulation requires the Commission to rescale the existing labels for five priority product groups, including lighting, by 2 November 2018 at the latest, to remove the A+ to A+++ classes.

Label effectiveness 

More generally, the filling up of the top classes means that the label is no longer effective. If there is still a significant difference in energy efficiency of products remaining on the market, a label will still bring added value in terms of guiding consumers to more efficient products.

2.Problem definition

The review of the ecodesign and energy labelling for lighting products started in 2015 and several studies were conducted for this purpose, as described in Annex 1. These studies evaluated the impact of the current legislation, as reported in Annex 9; they also looked at the technological and economic evolution of the sector and at stakeholders' views. Results from the studies have been used directly as input to the problem definition analysis model (see Annex 4).

The review process for lighting products ran for longer than usual for a product group in scope of ecodesign and energy labelling and had two Ecodesign Consultation Forums (in December 2015 and in December 2017, see Annex 2 and Annex 5), while usually only one is needed. This happened to take properly into account all relevant aspects and shape the problem definition.

The main finding from the evaluation of the impact of the current legislation is that electricity savings due to the existing requirements were expected to be 110 TWh in 2020, but according to the latest estimation they will be limited to 70 TWh. The evaluation showed that the gap in energy savings is the result of:

·Insufficient market surveillance by Member States;

·Too many parameters to verify by market surveillance, and too expensive/long verification testing required (e.g. 6000h test for lumen maintenance);

·Unclear definitions for exempted lamp types ("special purpose lamps", as defined in the current legislation), using a description of intended use rather than measurable parameters;

·Tolerances intended for use by market surveillance during verification that have been used also by manufacturers in the declaration of lamp characteristics, with the result to bring on the market products with an efficacy that is lower than the minimum required one;

·Recent appearance on the market of ‘fully-integrated luminaires’ from which the light source cannot be removed for compliance verification.

Moreover, incandescent lamps, which the ecodesign legislation phased-out from 2009, were expected to be mainly replaced by compact fluorescent lamps. However, many consumers preferred the less energy-efficient halogen lamps. Fluorescent lamps have not been adopted as expected because of (real or perceived) sub-standard performance (e.g. colour rendering and temperature, ignition time, mercury hazards).

The options presented in Section 5 were built on the outcome of the review to address the above listed concerns.

2.1.Problem 1: Outdated energy efficiency requirements

The problem: 

The current ecodesign requirements for lighting products no longer capture cost-effective energy savings and the current energy label no longer allows consumers to differentiate sufficiently between the products on the market.

In 2008, prior to the entry into force of the current Ecodesign and Energy Labelling Regulations in 2009 and 2012 respectively, there were 9.2 billion light sources operating in EU28, consuming 330 TWh/a of electricity. Without the current Regulations, in 2015 the electricity consumption of light sources in scope would have been 41 TWh higher (377 TWh instead of 336 TWh – see ‘BAU2008’ in 
[Figure 3](#_Ref511053948)
)
[26](#footnote26)
, equivalent to the total final electricity consumption of Denmark and Lithuania together. Savings happened despite the fact that the number of light sources had increased to 11.4 billion (+23.7% compared to 2008; +3.1% per year). Ecodesign and energy labelling measures have also reversed the growth trend of electricity consumption for light sources faster than under business-as-usual conditions.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48005.jpg)

Figure 3: Energy consumption of lighting products in scope of ecodesign – MELISA modelling, 2017 data

Nevertheless, lighting remains the second
[27](#footnote27)
 largest electricity consumer in the EU ecodesign programme (around 12% of all gross electricity production in the EU28
[28](#footnote28)
).

Moreover, the energy label for luminaires does not necessarily drive the consumer towards the most energy-efficient option: this label is different from a normal energy label, because it informs customers on the compatible light sources and on the possibility to remove the light source but not on the energy consumption of the luminaire.

The drivers of the problem:

Driver 1: Technological progress. Technology for light sources keeps evolving, thereby improving energy efficiency. LED technology, which is for almost all applications the most energy efficient lighting technology that exists, has had a rapid uptake on the EU market: from 0% of sold lamps in 2008 to 22% in 2015 with models on the market often being replaced by updated versions every six months to one year. In addition the average energy efficiency of LEDs quadrupled
[29](#footnote29)
 between 2009 and 2015, and prices dropped significantly: compared to 2010, in 2017 a typical LED lamp for household use was 75% cheaper and a typical LED lamp for offices 60% cheaper.

As a result of this technological progress the top three energy efficiency classes of the energy label are overpopulated: they cover 66% of the models and all LEDs are in these three classes. By 2020 over 50% of LEDs will be A++
[30](#footnote30)
. This makes it more difficult to distinguish between models. Moreover, the "A+", "A++" and "A+++" classes introduced by the Energy Labelling Framework Directive (Directive 2010/30/EU)
[31](#footnote31)
 have been shown to be less effective in persuading consumers to buy more efficient products than the A to G scale, with consumers wrongly believing that there is not much difference between A and A+++ 
[32](#footnote32)
.

Driver 2: Additional use functions. New features to make lights more "human centred" and "smart"
[33](#footnote33)
 have been added to lighting products since the adoption of the Ecodesign and Energy Labelling Regulations. The new functionalities have an impact on the energy efficiency of the lighting products but are not reflected in the existing energy efficiency calculations.

Driver 3: Current focus on household lighting. 2/3 of the energy savings achieved by the current legislation come from the residential sector, because of the existing ecodesign requirements for incandescent and halogen lamps, which are typically used for household lighting. However, 80% of lighting electricity is now consumed in the non-residential sector, 60% of this by linear fluorescent lamps (including the typical T8 fluorescent tube lights in offices
[34](#footnote34)
)
[35](#footnote35)
. Without an update of the requirements, the energy savings potential of non-residential lighting will not be realised at the required pace to contribute to the EU 2030 energy and greenhouse gas emissions reductions goals.

How the problem will evolve:

Ecodesign is a key driver for innovation in product energy efficiency and supports the EU’s technological and environmental leadership. The EU lighting regulations are generally in line with worldwide regulation and in some cases cover a wider scope of light sources or set more stringent requirements
[36](#footnote36)
.

Without requirements adapted to technological progress, light sources used in the EU are expected to be less energy efficient than they could be, and EU consumers will lose out from buying slightly cheaper but more energy consuming products, because the lifecycle costs which include energy consumption will be higher. Without improved legislation, the potential to save energy would not be reached in time to contribute to achieving the EU’s energy and greenhouse gas emissions reductions goals for 2030.

Finally, light sources used in the EU could become less energy efficient than in other economies such as US and Australia
[37](#footnote37)
 
[38](#footnote38)
. As a result, the EU could become a dumping ground for less efficient products that can no longer be sold in other parts of the world.

2.2.Problem 2: Burdensome implementation and surveillance 

The problem:

Practice shows that compliance with current Ecodesign legislation for lighting products can be difficult. Stakeholders have complained that (i) the norms are scattered between legislative texts, (ii) the scope and exemptions are not always clear and (iii) conformity assessment is demanding. Industry reported having problems in implementing this legislation and Market Surveillance Authorities (MSAs) encounter difficulties evaluating if products are in scope and in performing proper surveillance.

In addition, industry (mostly SMEs) find the Energy Label for luminaires a burden with limited added value. Many MSAs also find the verification of this label not worth the effort and consider that their enforcement efforts should rather focus on other aspects which would achieve more energy savings.

The drivers of the problem:

Driver 1: Complex legislation. Ecodesign requirements for lighting products are laid down in three different regulations: Commission Ecodesign Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012. This creates uncertainty as to the applicable regulation to specific products
[39](#footnote39)
. Furthermore, each regulation has its own formulae to calculate energy efficiency.

Driver 2: Unclear scope. The way that some exemptions are formulated makes the inclusion of certain products in the scope uncertain. In particular, "special purpose lamps" are exempted only on the basis of their "intended" use, which is a subjective test. It is not unusual to have special purpose lamps marketed for general lighting applications, thereby circumventing the minimum requirements that should apply to them. One example are the ‘special purpose lamps’ intended for ovens, which are incandescent lightbulbs because they have to withstand high temperatures. Nevertheless, they are also sold for general lighting purposes because they are compatible with some normal luminaires, thereby circumventing the ban on incandescent lightbulbs for general lighting
[40](#footnote40)
. Another example comes from the special purpose lamps for stage/studio/theatre lighting, especially the tungsten halogen lamps. The estimate for the energy consumption of special purpose lighting for movie/TV or photo studio/theatre/event applications is a small part of the total energy consumption for lighting products (0.075 TWh/y for special purpose lamps in theatres, compared to the total 336 TWh/y for all lamps as shown in Figure 3). Nevertheless, certain exemptions in the current Regulation, including the one on stage/studio/theatre lighting, have been used as loopholes. It is not uncommon to find installations of stage/studio/theatre lighting in residential apartments. Stakeholders, including the lighting industry, are keen for the revised legislation to close such loopholes.

Driver 3: Long and expensive testing. The number of parameters for compliance testing and the length of the test procedures make conformity assessment expensive and time-consuming. This is particularly true for the 6000 hours testing for the lamp survival factor and lumen maintenance. By way of illustration, LED lamp models have often sold out by the time the testing by MSAs is completed.

How the problem will evolve:

Electricity savings due to the existing regulations were expected to be 110 TWh in 2020
[41](#footnote41)
, but according to the last estimation they will be limited to 70 TWh. Ambiguities in the legislation on special purpose lamps and hampered capacity of MSAs to check compliance are relevant causes, especially because many lamps exempted for special purposes are energy inefficient incandescents
[42](#footnote42)
 and as exempted products they are therefore not subject to minimum energy efficiency requirements.

2.3.Problem 3: Limited energy savings and circular economy potential from non-dismountable products

The problem:

Sales of luminaires with separate, replaceable light sources are shifting towards non-dismountable LED luminaires (also known as fully integrated luminaires). With these devices, when the contained light source fails, the entire luminaire has to be replaced.

This trend is taking place because an integrated design offers advantages for energy efficiency and safety, and because LED light sources have longer lifetimes than classical technology light sources. Because these lifetimes are closer to the useful lifetime of the luminaire, it is often superfluous to make the light source replaceable. But integrated LED luminaires may still fail or be damaged. Representatives of lighting designers reported on various occasions during the review process
[43](#footnote43)
 that practical problems have arisen where large quantities of integrated luminaires were bought for an office or a shop: some luminaires failed prematurely (for various reasons), but the same luminaire model was not available anymore, requiring the user to replace it by another type or even to replace all luminaires when the lighting effect could not be the same.

The Energy label for luminaires provides information to consumers about the possibility of removing the contained light source, but this is not enough to avoid unwanted waste because non-dismountable products hamper replacement and recycling
[44](#footnote44)
.

The problem is even bigger when considering all the non-dismountable furniture products containing a light source (e.g. shelves, mirrors, etc.).

The current regulations impose ecodesign requirements on light sources wherever they are contained. But in practice MSAs may not be able to test them because they cannot access them. In practice, those light sources cannot always be monitored, and this creates an unfair level playing field compared to the same light source type which is accessible (e.g. because it is sold separately).

Addressing the issue of non-dismountable luminaires, and other products containing light sources, would help the development of products that are dismountable, and thus reparable, better recyclable and with the option to replace the contained light source. This will contribute to a Circular Economy.

The drivers of the problem:

Driver 1: Increase on the market of fully integrated luminaires. According to a survey by EU consumer association ANEC/BEUC on LED luminaires, in 2016 removability of light sources was not possible in 40% of the cases, compared to 30% in 2015.

Driver 2: Thermal characteristics of LEDs. Many luminaires are manufactured so that LED light sources are tightly mechanically integrated to optimise thermal management and for protection purposes. The side effect of this technology solution is that the unsealing and resealing of LED lights in the luminaire may hamper their energy efficiency.

How the problem will evolve:

With the growing trend of fully integrated luminaires on the market, the situation will become worse if no action is taken.

2.4.General market failures

In addition to the product specific problem drivers described in Sections 2.1, 2.2 and 2.3, some general market failures have been identified:

Myopic behaviour - Without up to date energy efficiency requirements and energy labels, economic actors (both business and private) will not choose the product that is the most cost-effective over the product's life-time. This is because economic actors are limited by the information they have, their knowledge about products, and the finite amount of time they have to make a decision.

Split incentives – Without up to date energy efficiency requirements, the guarantee that the products will be cost-effective over their life-time is lost. This is especially important for a certain group of consumers, in particular those in a landlord-tenant situations, where the landlord buys the appliance and the tenant pays the energy bill.

Price reflection – The price of the products does not reflect the real environmental costs to society in terms of circular economy. Hence, without setting requirements that will improve circular economy aspects of the product, the different actors in the life cycle of the appliance will not be incentivised to improve the circular economy aspects of the appliance.

2.5.Who is affected by the problems?

2.5.1.Manufacturers 

Manufacturers of lighting products include manufacturers of light sources, manufacturers of lighting-related electronics and manufacturers of luminaires
[45](#footnote45)
. More information on employment and the size of the lighting products market can be found in Annex 6.

As for manufacturers of light sources, the EU28 employment in the light sources industry is 60 000 jobs (1/3 direct manufacturing, 1/3 OEM
[46](#footnote46)
 and 1/3 services: worldwide the total is 194 000). The major suppliers of light sources in EU28 are Philips Lighting
[47](#footnote47)
, Ledvance/Osram, General Electric (GE) Lighting
[48](#footnote48)
 and Feilo-Sylvania. Together, they make EUR 3 billion of estimated revenue from the sale of light sources for general lighting, directly employ 15 000 people in direct manufacturing and generate employment for further 30 000 people (in OEM and services)
[49](#footnote49)
.

The largest part of the production chain for LEDs is in Asia, while European companies tend to specialise in high quality LEDs with new features (e.g. "smart lights"). Some European companies have sold their general lighting business in the last years, especially to Asian companies.

Asian manufacturers are rapidly expanding their global market share, using price as their main selling point. The energy label and ecodesign requirements play a crucial role for EU industry, to distinguish itself based on quality and innovation.

With the ongoing rapid shift to LED lighting, manufacturers of lighting-related electronics are required to adjust from electronic control gears for classical lighting technologies to drivers for LEDs. Less efficient electro-magnetic control gears are being phased out from the market since 2017 and have been replaced by more efficient, high-frequency electronic ones. These manufactures have a dynamic business also due to the increasing trend to have ‘smart lights" with new features.

Manufacturers of luminaires are mostly SMEs. The EU luminaire market is very fragmented: the ten largest European manufacturers cover 45% of the total market
[50](#footnote50)
. Manufacturers of luminaires say they find it burdensome to implement the current energy labelling regulation.

2.5.2.Consumers

For consumers
[51](#footnote51)
, the energy label offers a unique opportunity to make an informed choice as to which products offer the best energy performance allowing them to save money in the long run. Ecodesign requirements safeguard consumers from the worst performing products.

The new features that are increasingly included in LED lamps (e.g. dimming, change of colour or white-tone by remote control, etc.) allow consumers to create their desired functionality and ‘atmosphere’; but as the energy consumption or quality characteristics of such features are not considered in the current legislation, consumers do not get the full picture from the existing information and energy scale.

The increasing number of fully integrated luminaires from which the light source is not removable, could mean more costs for consumers.

In 2015, the average European household spent EUR 113 for lighting (acquisition and energy costs).

2.5.3.Market Surveillance Authorities

The complex legislation and the increasing popularity of non-dismountable LED luminaires hampers compliance checks by national market surveillance authorities.

2.5.4.Society as a whole

For society as a whole, ambitious policies in the area of energy efficiency are important tools to mitigate climate change. Effective and efficient energy labelling and ecodesign regulations contribute to achieving goals set in the Paris Agreement and they help achieve the 2030 EU climate and energy goals
[52](#footnote52)
.

3.Why should the EU act?

3.1.Legal basis

The legal basis for acting at EU level through the Ecodesign framework Directive and the Energy Labelling framework Regulation is Article 114 and Article 194 of the Treaty on European Union and the Treaty on the Functioning of the European Union (TFEU)
[53](#footnote53)
 respectively. Article 114 relates to the "the establishment and functioning of the internal market", while Article 194 gives, amongst others, the EU the objective "in the context of the establishment and functioning of the internal market and with regard for the need to preserve and improve the environment" to "ensure security of energy supply in the Union" and "promote energy efficiency and energy saving and the development of new and renewable forms of energy".

The Ecodesign Framework Directive and Energy Labelling Framework Regulation include a built-in proportionality and significance test. For the Ecodesign Framework Directive, Articles 15(1) and 15(2) state that a product should be covered by an ecodesign or a self-regulating measure if the following conditions are met:

·The product should represent a significant volume of sales;

·The product should have a significant environmental impact within the EU;

·The product should present a significant potential for improvement without entailing excessive costs, while taking into account:

o an absence of other relevant Community legislation or failure of market forces to address the issue properly,

oa wide disparity in environmental performance of products with equivalent functionality;

The procedure for preparing such measures is described in Article 15(3). In addition, the criteria of Article 15(5) should be met:

·No significant negative impacts on user functionality of the product;

·No significant negative impacts on Health, safety and environment

·No significant negative impacts on affordability and life cycle costs

·No significant negative impacts on industry’s competitiveness (including SMEs).

The Energy Labelling Framework Regulation includes similar criteria for products covered by an energy label, in Article 16(2):

·The product group should have significant potential for saving energy and where relevant, other resources;

·Models with equivalent functionality should differ significantly in the relevant performance levels within the product group;

·There should be no significant negative impact as regards the affordability and the life cycle cost of the product group;

·The introduction of energy labelling requirements for a product group should not have a significant negative impact on the functionality of the product during use.

During the review process (Review study 2015), it was established that lighting products fulfil the above eligibility criteria.

3.2.Subsidiarity: Necessity of EU action

Action at EU level gives end-users the guarantee that they buy an energy efficient product and provides end-users with harmonised information no matter in which MS they purchase their product. This is becoming all the more relevant as the online trade increases. With ecodesign and energy labelling at EU level, energy efficient products are promoted in all MSs, creating a larger market and hence greater incentives for the industry to develop them.

It is essential to ensure a level playing field for manufactures and dealers in terms of requirements to be met before placing an appliance on the market and in terms of the information supplied to customers for sale across the EU internal market. For this reason EU-wide legally binding rules are necessary.

Market surveillance is carried out by the MSAs appointed by MSs. In order to be effective, the market surveillance effort must be uniform across the EU to support the internal market and incentivise businesses to invest resources in designing, making and selling energy efficient products.

Regulation (EU) 2017/1369 requires the Commission to update the current energy labelling regulation for lighting products, in particular as regards rescaling the label to remove the A+ and A++ classes.

3.3.Subsidiarity: Added value of EU action

There is clear added value in requiring minimum energy efficiency levels and energy label class limits at EU-level.

Without harmonised requirements at EU level, Member States would be incentivised to lay down national product-specific minimum energy efficiency requirements in the framework of their environmental and energy policies. This would undermine the free movement of products. Before the existing ecodesign and energy label measures were implemented, this was in fact the case for many products.

4.Objectives: What is to be achieved?

4.1.General objectives

Following the legal basis in the TFEU, the general objectives are to:

1.Facilitate free circulation of efficient lighting products within the internal market;

0.Promote competitiveness of the EU lighting products industry through the creation or expansion of the EU internal market for sustainable products;

1.Promote the energy efficiency of lighting products as a contribution to the Commission's objective to reduce energy consumption by at least 30% and domestic greenhouse gas (GHG) emissions by 40 % by 2030; implement the energy efficiency first principle established in the Commission Communication on Energy Union Framework Strategy; and

2.Increase energy security in the EU and reduce energy dependency through a decrease in energy consumption of lighting products.

There are several synergies between these objectives. Reducing electricity consumption (by increasing the energy efficiency) leads to lower carbon, acidifying and other emissions to air. Tackling the problem at EU level enhances efficiency and effectiveness of the measure.

4.2.Specific objectives

The specific objectives of the policy options considered in this impact assessment are to correct the problems identified in the problem definition (Section 2):

·Update the energy efficiency requirements and the energy label in line with international and technological developments, and the revised Energy Labelling framework Regulation, to achieve further cost-efficient energy savings;

·Redefine the scope and the exemptions to reduce the administrative burden and close loopholes, to better protect consumers and to make the obligations clear to manufacturers and MSAs;

·Contribute towards a circular economy in the EU by including requirements for non-dismountable products containing light sources.

5.What are the available policy options?

The procedure for identifying policy options follows from the Better Regulation Toolbox
[54](#footnote54)
. Specific measures in the policy options are the result of a combination of initiatives mentioned in the Review study 2015, the evaluation in Annex 9, the Inception Impact Assessment
[55](#footnote55)
, and inspiration taken from the Ecodesign Framework Directive and the Energy Labelling framework Regulation. They aim to address the issues identified in Section 2 and achieving the objectives defined in Section 4.

Figure 4 shows the link between the problems, the drivers, the specific objectives and the possible measures to tackle the problems. For every option, Section 5.2 describe the proposed measures.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48006.jpg)

Figure 4: Link between the problems, drivers, objectives and measures

Some measures presented in this impact assessment were extensively discussed with stakeholders during two Consultation Forums (7 December 2015 and 7 December 2017) and represent the consensus achieved. They apply to all policy options and are further detailed under option 2 – ELOnly and Option 3 – ECOEL2021
[56](#footnote56)
. The main element that needs to be further assessed is the timing for the phase out of linear fluorescent T8 lamps (see Options 3 and 4).

Subsequently, the policy options considered for this impact assessment are listed in 
[Table 1](#_Ref517466979)
 (detailed description in the next sections): 

Table 1: Policy options

|  |  |  |  |
| --- | --- | --- | --- |
| Option | Name | Short name | Description |
| Option 1 | Baseline (Business as usual) | BAU | No further action, the regulations currently in place remain unchanged |
| Option 2 | Energy Label only | ELOnly | Only the Energy labelling regulation is reviewed with application from 09/2021; the ecodesign requirements remain unchanged |
| Option 3 | Ecodesign & Energy Label 2021 | ECOEL2021 | Both Ecodesign and energy labelling are reviewed, with application from 09/2021. Option 2 is encompassed in Option 3. |
| Option 4 | Ecodesign & Energy Label 2021-23 | ECOEL2tiers | Similar to Option 3, except for the timing for phasing out the fluorescent T8 lamps which would occur in 09/2023 [57](#footnote57) |

5.1.What is the baseline from which options are assessed?

In the baseline, the current Ecodesign and Energy Labelling Regulations and all other relevant EU-level policies and measures are assumed to continue without revision.

In the baseline a shift towards LED lighting products will anyway happen, at a pace that is derived from current trends in sales, efficiency increase and price decrease. These trends are different for residential and non-residential applications.

The new Framework Regulation also prescribes the creation of a database (called EPREL) with information on all products in scope of delegated acts on energy labelling. The proposed act on lighting products specifies the information to be entered in this database.

The requirement in the ETS to reduce emissions (from amongst other electricity production) will impact lighting products in a baseline scenario. Indeed, inefficient lighting products lead to more energy consumption. More electricity consumption increases the demand for ETS allowances. This either leads to higher ETS prices (which could in turn increase electricity prices) or to the need for additional emission reductions in ETS sectors (higher renewable energy targets or more reductions in industry).

5.2.Description of the policy options

5.2.1.Option 1 – Baseline (BAU)

Option 1 is the baseline for the impact assessment as described in Section 5.1. None of the measures in Figure 4 is implemented.

5.2.2.Option 2 – Energy label at 2021 (“ELonly”)

Under Option 2, only the energy labelling legislation will be updated, while the ecodesign requirements would stay unchanged. 
[Table 2](#_Ref510800719)
 below depicts the link between the different problems identified in Section 2 and the proposed measures under Option 2.

Table 2: Proposed measures under Option 2

|  |  |
| --- | --- |
| Identified problems | Corrective measures |
| Problem 1: Outdated energy efficiency requirements | 2. Updated Energy Label |
|  | 3. Updated formula (for energy label) |
| Problem 2: Burdensome implementation and surveillance | 6. Discontinued energy label for luminaires |
| Problem 3: Limited energy savings and circular economy potential from non-dismountable products | 7. Luminaires treated as "light sources" when not dismountable (for energy label) |

Measures related to problem 1

Measure 2: Updated energy Label – Framework Regulation (EU) No 2017/1369 requires a rescaling of energy efficiency classes for light sources, from an A++ to G scale to an A-G scale by 2 November 2018. Class limits are to be set such that at the introduction of the rescaled label (2021) the A and B classes are empty, while the estimated time within which a majority of models falls into class A is at least 10 years later. The limits for the energy efficiency classes have been defined directly in terms of light source efficiency, as a result of the total light output of a light source (in lumen, lm) divided by the mains (230V) power input (in Watt, W) and expressed as lm/W.

All light source models with efficacy below 85 lm/W will be class G. To obtain an A classification, a light source shall have an efficacy of at least 210 lm/W. Class widths are constant at 25 lm/W. As of October 2017 there are no light sources on the market that can meet the efficiency limits of classes A and B (but there are at laboratory level), so these classes would initially be empty as required by Regulation (EU) 2017/1369. The best LED light sources typically used by households today on the market would have new label class E; the best LED light sources for professional use today on the market would be class D and by 2021 some would be expected to be class C. In 2021, when the new classes will start to apply, class A is still expected to be empty while there might already be some class B light sources on the market.

Table 3: LLCC - Energy efficiency classes

|  |  |
| --- | --- |
| Energy efficiency class | Total mains efficacy TM (lm /W) |
| A | 210 ≤ TM |
| B | 185 ≤ TM < 210 |
| C | 160 ≤ TM < 185 |
| D | 135 ≤ TM < 160 |
| E | 110 ≤ TM < 135 |
| F | 85 ≤ TM < 110 |
| G | TM < 85 |

Table 4 gives an overview of the action that needs to be undertaken.

Table 4: LLCC, Energy efficiency requirements and Energy label - Who, what and by when

|  |  |  |  |
| --- | --- | --- | --- |
|  | Action | Who | By When |
| Energy Label | Provide the updated energy labels with the product | Supplier | 1 May 2021 [58](#footnote58) |
|  | Display the updated energy labels with the product | Dealer | 1 September 2021 |
|  | Remove products from the shelves if they do not have the new label | Dealer | 1 June 2022 |

Following the outcome of the 2015 Review study, the measure aims in particular to increase the visibility of the label (e.g. arrow on front of package).

The energy label for lighting products is typically printed on the package of the product. Suppliers and dealers have shown concerns about how in practice to re-scale lighting products with the new energy label. The proposal to apply stickers on the products that at the date of application of the new label will be on shelves got much criticism at the Consultation Forum of December 2017 (see Annex 5) from almost all stakeholders. According to the new Framework Regulation (EU) 2017/1369 (art. 11(13)), specific rules can be provided for energy labels printed on the packaging, like in the case of lighting products. The proposed derogation for this measure is to put a deadline of nine months to dealers, after which the products can no longer be sold unless a rescaled label is attached on their package
[59](#footnote59)
.

Measure 3: Updated formula
[60](#footnote60)
 for energy label - A new formula for energy labelling is proposed that better reflects energy efficiency and is more intuitive in the calculation than the Energy Efficiency Index set out in the current energy labelling regulation. In the new metrics the limits for the energy efficiency classes have been defined directly in terms of light source efficiency, as a result of the total light output of a light source (in lumen, lm) divided by the mains (230V) power input (in Watt, W) and expressed as lm/W. This change implies that light sources with high light output do not need a higher efficiency to obtain a given energy efficiency class than light sources with low light output. This is reasonable considering that when the new energy labelling requirements start to apply, the label classes’ main purpose will be to differentiate between LEDs according to their respective efficiencies
[61](#footnote61)
.

The introduction of the new metrics is not an additional burden on the manufacturers, importers and suppliers as they already have to compute them under the current regulations. In conclusion, the new metrics reflect technological progress and improve the transparency. A comparison of the proposed and old formulae is given in Annex 10.

Measure related to problem 2

Measure 6: Discontinued energy label specifically dedicated to luminaires.

These are three ways of showing the energy label for luminaires today:

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48007.jpg)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48008.jpg)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48009.jpg)

As explained in Section 2.2, the energy label for luminaires is often considered a burden for SMEs and MSAs, and does not necessarily drive the consumer towards the most energy-efficient solution. Indeed, contrary to the lamp label, the luminaire label does not show the energy consumption of the luminaire, but rather inform consumers on the energy class of the compatible and/or contained light sources. In addition, the current label also informs consumers when the light source cannot be removed. However, other relevant information is missing on the luminaire label: the compatible/contained light source type and technology
[62](#footnote62)
.

In the interest of consumers, even if the label for luminaires is discontinued, relevant information from the current label, as well as additional information, should still be provided on the package, namely: (i) in case the luminaire is sold with a light source inside, the energy class of the contained light source; (iii) the compatible/contained light source type and technology; and (iii) if the light source can be removed.

Measure related to problem 3

Measure 7: Fully integrated luminaires to be treated as light sources – Fully integrated luminaires will be considered a light source for the purposes of the energy labelling legislation and will be required to have an energy label. This measure will: (i) resolve the problem that MSAs have to test light sources when these are not accessible; (ii) resolve the issue of an unfair level playing field for industry when the same light source type is accessible; and (iii) support consumers in their conscious choice when buying integrated luminaires; In the longer run this measure will also stimulate innovation in LEDs, in particular towards thermal interfaces for LED modules that maintain their thermal dissipation characteristics when unmounted and remounted and, consequently, will reduce waste from old or damaged luminaires that cannot be refurbished or repaired.

As for all other products containing a light source (e.g. shelves, mirrors, etc. as well as the dismountable luminaires), this measure introduces the concept of the “containing product”. Manufacturers of the containing products will be obliged to add to the information material of the containing product which light source type is inside, what is its energy class and if it is removable or not.

Stakeholders view on Option 2 - ELOnly: All stakeholders think that it is likely that an Energy Label alone will not reach important parts of the market, that there will be missed savings and loss of competitiveness through dumping. Regarding the discontinuity of the energy label for luminaires, industry, notably SMEs, and MSAs welcome this measure. This measure was part of the online public consultation on the revision of the lighting legislation, whose respondents were mostly private citizens and NGOs. Respondents did not show a clear preference for an option (30% would like to keep the label as it is, while 28% would favour its replacement by a label that concerns only the light source which is contained inside; 37% had no opinion), but only 5% favoured to discontinue the label for luminaires without an alternative. The solution that meets all needs is to keep the most relevant information that the energy label for luminaires gives and improve it (as explained in Measure 6) but to remove the requirement to supply the label for luminaires.

5.2.3.Option 3 – Ecodesign and Energy label at 2021 (ECOEL2021)

As regards energy labelling, Option 3 - ECOEL2021 puts forward similar measures as Option 2. In addition, and in response to the stakeholders view expressed on the energy-labelling only scenario in 5.2.2, Option 3 integrates revised ecodesign requirements with application from September 2021.

Table 5 below shows the link between the different problems identified in Section 2 and the proposed measures under Option 3.

Table 5: Proposed measures under Option 3 – (measures in bold are specific to ecodesign. The other measures are encompassed from Option 2)

|  |  |
| --- | --- |
| Identified problems | Corrective measures |
| Problem 1: Outdated energy efficiency requirements | 1.Ecodesign energy efficiency limits |
|  | 2.Updated Energy Label |
|  | 3.Updated formula (for ecodesign) |
| Problem 2: Burdensome implementation and surveillance | 4.Redefined scope and exemptions |
|  | 5.Simplified tests |
|  | 6.Discontinued energy label for luminaires |
| Problem 3: Limited energy savings and circular economy potential from non-dismountable products | 7.Luminaires treated as "light sources" when not dismountable (for ecodesign) |

Option 3 would propose gathering all ecodesign requirements for light sources, for control gears and the correction factors in one single annex over three different tables. This will amount to a significant reduction of the dozens of pages contained in the relevant annexes in the current three Ecodesign regulations, making conformity assessment by industry and market surveillance by Member States easier.

Measures related to Problem 1:

Measure 1: Updated Ecodesign energy efficiency limits – As a general principle, it is proposed to have on the market only light sources that meet a certain minimum efficacy. The minimum efficacy is defined by means of a maximum power formula that uses =120 lm/W and L=1.5
[63](#footnote63)
 as constants and that, reflecting the state of technological progress, will take into account in the calculation:

·light source characteristics such as the emitted luminous flux;

·the directionality of the light;

·the ability to operate directly on mains power supply (230V);

·the ability to render colours; and

·the presence of special features (anti-glare shield, tuneable colour, network connections).

For details, see Measure 3: Updated formula.

The energy efficiency requirements proposed in Measure 1 will no longer allow on the market linear fluorescent lamps T8 with a length of 2-, 4- or 5-feet
[64](#footnote64)
, compact fluorescent lamps with integrated control gear (the old ‘energy saving lamps’ with slow start time), almost all remaining halogen light sources, and LED light sources with low efficiency. As of 2017, around 30% of the existing LED light sources would not meet the new proposed requirements. but with the rapid trend of new LEDs on the market this share is expected to decrease by September 2021. See Table 6.

Table 6: Proposed phased-out light sources at September 2021

|  |
| --- |
| LFL T8 2-, 4- and 5-foot length |
| HL low voltage directional (MR11-GU4, MR16-GU5.3, AR111-G53) |
| HL low voltage capsules (G4, GY6.35) |
| HL mains voltage capsules (G9) |
| HL linear R7s>2700 lm |
| CFLi |
| All other light sources which are not listed in Table 7 (including LEDs) and which do not meet the general minimum efficacy requirement based on the maximum power formula |

As exceptions to the general minimum efficacy requirement, T5 fluorescent light sources (mainly office use), high-intensity discharge light sources (mainly street lighting and industrial use), compact fluorescent lamps without integrated control gear (mainly tertiary sector) and linear halogen light sources (R7s cap) with less than 2700 lm light output (mainly household use) would continue to be allowed on the market. These light sources are not phased out because adequate higher efficiency LED light sources are not yet commonly available or not yet economically advantageous for the average user. Keeping lamps like T5 on the market avoids that users are requested too soon to switch again to another technology, following the application of the most recent ecodesign requirements.

Table 7: Light sources that would stay on the market as an exception to the general principle, their constants  and L used in the maximum power formula, and comparison with the current legislation

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48010.jpg)

Table 7 shows which light sources would stay on the market as an exception to the general minimum efficacy requirement and the values of constants  and L per type. For these light sources the minimum required efficacy is defined using the same maximum power formula, but with different values for the constants  and L. As a result, the required minimum efficacies are lower than the general requirement. As Table 7 shows, the constants  and L are in most cases tuned to closely match the existing requirements (where it reads "same level"). In practice nothing changes for these lamps compared to today. Where instead it reads "new", those lamps will still be allowed on the market, but with a higher minimum energy efficacy than today.

For control gears, the minimum efficiency requirements for halogen-, fluorescent- and HID-gear remain the same. The efficiency requirements for LED-gear are new.

Light sources that are no longer allowed on the market because they cannot meet minimum efficiency requirements of existing regulations will remain banned under the new regulation, i.e. there is no backsliding of requirements.

Measure 3: Updated formula for ecodesign – The proposed solution for ecodesign requirements on light sources that are today spread over three regulations entails a single formula defining the maximum allowed input power as a function of the emitted luminous flux
[65](#footnote65)
. The formula uses two constants (and L) whose values differ per light source type (see Table 7). In addition, there are three correction factors: F for use of flux in a cone instead of total flux (directional vs. non-directional light sources), R to reflect the influence of colour rendering characteristics (bonus for light sources with good colour rendering; penalty for bad colour rendering), and C as a correction factor (bonus) for special characteristics (see Annex 10).

Measures related to Problem 2:

Measure 4: Redefined scope and exemptions – Under this measure it is proposed to drop the criterion of “intended use” to define "special purpose lamp" and to replace it with clearer specifications to define what is exempted and what is in scope of the legislation. Exemptions, including for ‘special purpose lamps’, would depend on measurable parameters (spectrum, light-emitting surface area, luminous flux <60 or >100 000 lm, etc.), exclusive use for certain applications or certification. As a specific example, in the case of stage/studio/theatre lighting the exemption for tungsten lamps would be based on the socket type: this would avoid installations of specific lights for stage/studio/theatre in residential apartments, as explained in Section 2.2
[66](#footnote66)
.

Measure 5: Simplified tests – The tests to ensure the conformity of the products with the requirements are considerably modified, with the aim to reduce the burden on industry and help MSAs in their surveillance. The modifications to the tests are not lowering the ambition of the legislation. The main change is for the endurance testing: the proposed test will last half the time of the current one (3000 h vs. 6000 h) and will combine two tests which were developed in recent years (switching test and accelerated endurance test). The new endurance test will be for LEDs only. Other tests include the displacement power factor (limiting the disturbance of the electricity grid by LEDs), colour rendering index (ensuring good colour rendering for indoor light sources), colour consistency (limiting colour differences between LEDs of the same type), and flicker (ensuring absence of visible flicker for LED light sources). The proposal removes tests that have progressively lost their relevance (notably the start time test typical for fluorescents)
[67](#footnote67)
.

The procedure to be used by market surveillance authorities for compliance verification has been aligned with the common procedure for other Ecodesign products as introduced by Commission Regulation (EU) 2016/2282
[68](#footnote68)
.

Verification tolerances are made more specific, i.e. no longer a general 10% tolerance but a differentiation in the range of 2.5% to 10%, depending on the type of light source, parameter and possibly the power range. The number of test samples is reduced to 10, instead of 20. For expensive light sources the number of samples can be reduced to 3.

Measures related to Problem 3:

Measure 7: Fully integrated luminaires to be treated as light sources – Luminaires (more generically ‘containing products’) are not in scope of the current ecodesign legislation, but the light sources and separate control gears used inside them have to comply with the current ecodesign legislation. To enable verification of these contained parts, and for reasons of material resource efficiency (circular economy), this measure would provide for fully integrated luminaires to be considered as light sources for the purposes of the ecodesign regulation when the luminaire cannot be dismounted without mechanical damage. Fully integrated luminaires would be considered as light sources also for the purposes of energy labelling.

Energy labelling has in scope light sources. For fully integrated luminaires, the same as for ecodesign applies. Not all the products that are exempted in ecodesign would be exempted in energy labelling: this is to allow consumers to know the energy consumption of as many light sources as possible that are on the market.

Stakeholders view on Option 3 – ECOEL2021: Stakeholders support the revision of both ecodesign and energy labelling regulations. At the online public consultation on the revision of lighting legislation that ran until 7/5/2018, a high majority of respondents (75%) supported to update ecodesign measures for lighting to take into account technological development (only 11% answered no, see Annex 2). For non-LED light source types, stakeholders generally support to keep on the market HID, LFL T5, CFLni and to phase out CFLi and almost all remaining halogens. Stakeholders also support the take up of good quality LEDs. The timing for the phase out of T8 fluorescents is the most sensitive point, as some stakeholders question the availability of LED replacements for all applications using T8, but the date of September 2021 and targeted exemptions tackle most concerns of stakeholders (see the discarded option that proposed measures at September 2020 in Section 5.3.3).

5.2.4.Option 4 – Ecodesign and Energy label at 2021 and 2023 (ECOEL2tiers)

Option 4 is identical to Option 3, apart from the fact that it implements the requirements for T8 fluorescents two years later, i.e. in 2023 instead of 2021. The phase out of T8 lamps is the most relevant of the ecodesign measures: it would deliver 90% of the energy savings from lighting products in 2030. Postponing the phase out of T8 lamps would give the industry some extra time to prepare for the phase-out of T8 fluorescents, but it will come at a cost in terms of lower energy and emission savings, as explained in Section 6: it would mean missing 2-3 TWh of savings per year of postponement (for comparison: the electricity consumption of Malta in 2015). Many lighting companies are already commercialising LED replacements to T8. Lighting designers confirm that the vast majority of new installations use LEDs.

Stakeholders view on Option 4 – ECOEL2tiers: Part of the industry and a minority of Member States expressed preference for postponing the phase-out of T8 lamps to 2023, in particular to allow a smoother transition in some sectors. The majority of Member States supports an earlier phase-out together with targeted exemptions for problematic sectors. NGOs and consumers ‘associations oppose a late phase out of T8 lamps.

5.3.Options discarded at an early stage 

5.3.1.Voluntary agreement by the industry

A voluntary agreement has to be given priority according to the Ecodesign Framework Directive, provided it meets the objectives in a quicker and more cost-effective manner. Today minimum mandatory requirements are already in force. Since no proposal has been put forward by industry, there is no voluntary agreement that meet the conditions of the Ecodesign Framework Directive. As a consequence, this option is discarded from further analysis. When substituting mandatory requirements by a voluntary agreement there would be a risk of free riders
[69](#footnote69)
, in case not all actors present on the market would sign such an agreement and comply with it.

Stakeholders view: None of the stakeholders are in favour of voluntary agreements for the reasons set out above.

5.3.2.LLCC

The Ecodesign Framework Directive states that minimum efficiency requirements shall be set at the level of Least Life Cycle Costs (LLCC), relating to the economically most advantageous proposition for end-users. The 2015 Review study
[70](#footnote70)
 shows that for most household applications, LEDs already have the lowest life cycle costs. For professional applications, e.g. office lighting and street lighting, it depends on the application, but in many cases the classical technologies (fluorescent and high-intensity discharge lamps) still offer the lowest life cycle cost. This is expected to change by 2020, when payback times for an investment in LED for these applications will come down to two-three years. Hence, according to the LLCC-criterion, the minimum required efficiency for ecodesign could be set at a level that only LEDs would meet.

However, there are several reasons why an only-LED choice at this point would not be feasible. First, despite LED-lamps enjoying considerable commercial success, there is the legacy of an existing park of light sources, control gears and luminaires. More importantly, there are still applications for which LEDs are not yet suitable. Second, for large investments in lighting, professionals may also encounter problems in obtaining loans, as lenders thoroughly scrutinise any investment that is higher than the bare minimum on payback and return-on-investment. Finally, many businesses were incentivised by government programmes to invest in efficient fluorescent lamps (especially the “T5”) only a few years ago and need time to recuperate their investments. The same goes for municipalities that invested in new city street lighting after the phase out of high pressure mercury lamps from April 2015
[71](#footnote71)
.

Stakeholders view: Almost all stakeholders, including some environmental NGOs, agreed that the timing to phase out from the market all non-LED lights was too demanding. Some among the most environment-friendly stakeholders proposed to add to the new legislation an only-LED set of requirements at a later stage (2023 or 2024).

5.3.3.Ecodesign and energy labelling at 2020

At first instance, the European Commission suggested at the Consultation Forum of December 2017 to apply Option 3 described in Section 5.2.3 as of September 2020, i.e. a year earlier than what is presented in this Impact Assessment. The main reason for discarding this option is to allow one more year for more good quality LEDs to come to the market that would replace the proposed-to-be phased out technologies, especially fluorescents. The phase-out of fluorescents would be as important as the ban of incandescents that happened from 2009. Fluorescent lamps well served the purpose to help with the phase-out of energy-inefficient incandescent lamps, but fluorescents have not been adopted as expected because of (real or perceived) sub-standard performance (e.g. colour rendering and temperature, ignition time, mercury hazards). Consumers bought less energy-efficient halogen lamps instead. As LEDs would play the role to replace fluorescents, like fluorescents played the role to replace incandescents, it is important not to ban fluorescents too early.

Stakeholders view: Relevant stakeholders, including industry and some Member States normally known to support ambitious environmental policies, commented that September 2020 would be too early to implement the proposed requirements. See Annex 5 for the minutes of the Consultation Forum.

5.3.4.Ecodesign only

The Ecodesign only option would introduce new measures for ecodesign only and leave unchanged the current legislation for energy labelling of lighting products. This option was discarded for the following reasons:

1. Over 11 TWh of electricity savings at 2030 would be missed if the energy labelling measures were not updated (see Section 6.2.1 for details);

2. Without an update label, consumers will not be able anymore to make an informed choice based on energy-efficiency performance. As shown in Section 2.1, today the top three energy efficiency classes of the energy label are overpopulated: they cover 66% of the models and all LEDs are in these three classes. By 2020 over 50% of LEDs will be A++
[72](#footnote72)
. In conclusion, there is still significant difference in energy efficiency between the products remaining on the market to justify an energy label. Without an updated energy label, consumers will base their choice solely on price and the pull mechanism created by energy labelling will disappear.

3. Last but not least, the EU legislator already decided on framework legislation governing this initiative. Lighting was identified as a priority group for the rescaling of the energy label by 2 November 2018 (Regulation (EU) 2017/1369). An "Ecodesign only" option would have to be discarded anyway to comply with framework Regulation.

6.What are the impacts of the policy options?

6.1.Methodological considerations and key assumptions 

With the adoption of the Ecodesign Working Plan 2016-2019 in November 2016, the Commission committed for the first time explicitly to systematically exploring resource efficiency requirements in ecodesign. As a result, the methodological basis for the inclusion of such requirements is not yet fully developed; there are no well-established and accepted methodologies in place to identify requirements in the context of mandatory legislation (contrary to green public procurement, ecolabels, etc.).

Therefore, the ‘circular economy’ requirements that are proposed are based in particular on stakeholder input, existing studies and evidence of product failure (e.g. on spare parts), and focus on measures that can be relatively easily implemented. As such, they can be considered a starting point that can subsequently be complemented or refined when the methodological tools are available.

There is also a lack of methodologies to ‘quantify’ the costs and benefits of such criteria in the context of the ‘least life cycle cost’ (LLCC) calculations applied for energy efficiency in ecodesign, in particular as regards the assessment of trade-offs.

Although a fully quantified impact assessment of such requirements has not been possible at this stage, a qualitative impact assessment was made, based on inputs taken from technical, scientific and policy-making literature, and nascent evidence from other similar product groups. This forms the basis of an assessment, which can be refined over time in due course, to be supplemented with actual quantitative data collected via the monitoring and the evaluations. These data will also serve at the time of the next revisions of the product regulations.

To address the gaps in the methodological framework, the Commission mandated CEN/CENELEC to develop standards for material efficiency under ecodesign and a first set of horizontal standards is expected next year, in 2019. These will be integrated in the MEErP methodology as appropriate. A broader update of the MEErP is foreseen in 2019, in particular to see how circular economy aspects could be better integrated in preparatory and review studies, and the LLCC calculations.

The scenario analysis for this impact assessment has been performed using the ‘Model for European Light Sources Analysis’ (MELISA). The input data for the model (e.g. annual sales volumes, average luminous flux, power and efficacy, light source prices, etc.) have been extensively checked against other data sources
[73](#footnote73)
 and discussed with stakeholders. In July 2016 this resulted in an updated MELISA version, incorporating new input data supplied by industry association LightingEurope
[74](#footnote74)
, and implementing an enhanced method to compute the installed stock of light sources from the annual sales and (variable) lifetimes. A further update took place in October 2017 as regards the projections for the development of average LED efficacy and price. The projection curves were adapted to match the average LED efficacy derived from 2015-2017 catalogue data and taking into account recent projections from UNEP and US DoE 
[75](#footnote75)
. A separate projection curve was created for directional lamps. In addition, electricity rates were updated from Eurostat data.

MELISA derives the installed stock of light sources in the EU28 from data on the annual sales and on the average useful lifetimes. These stock data are combined with average unit power values (W) and average annual operating hours per unit (h/a) to compute the total electricity consumption per base case (TWh/a). The contributions of the various base cases are summed up to arrive at the EU28 totals for all sectors. The shift in (light source) sales from the classical technology base cases to the LED base cases of the same group is one of the essential elements in the scenario projections in MELISA.

Greenhouse gas (GHG) emissions are directly related to electricity consumption by means of the Global Warming Potential (GWP) for electricity.

As regards the main limitations, risks and uncertainties of MELISA, the methodology itself (largely based on the MEErP) is sound, but as with any model, the results depend on the quality of the input data. The data was extensively checked during the review study and largely agreed with stakeholders to mitigate the risk from the quality of input data.

A second factor is the uncertainty about the future development of electricity prices. MELISA uses the price projections from the MEErP (with a 4% annual escalation rate), while the PRIMES
[76](#footnote76)
 projection for electricity prices have a much lower escalation rate. However, a sensitivity analysis was performed using the PRIMES process for all options and the results are reassuring: the overall trend is confirmed and the classification of the options according to their monetary savings does not change when using PRIMES electricity rates instead of MEErP electricity rates (see Annex 4.9).

Third, as regards lighting in non-residential buildings, there is uncertainty about the average annual operating hours for lighting. The MELISA model could not be used because MELISA follows a conservative approach with relatively low operating hours, meaning that non-residential electricity consumption and savings might be underestimated. To overcome this problem, a separate estimate of the electricity consumption was made by using a completely different methodology. This used the building areas per type of space/activity derived from the Building Heat Demand report, lighting level requirements per type of space/activity from standards, and parameters and procedures from standard EN 15193. Following this method, using higher non-residential operating hours would not change the choice of the preferred option, but rather reinforce it.

More generally, the MELISA model has been used not only in the study on lighting products, but also in the Ecodesign study on lighting systems and in the study on the impact of RoHS-measures on light sources. The industry organisation LightingEurope examined the model in detail and largely supports it. This shows that there is confidence in the robustness of the model data.

The analytical methods used to determine the impacts are described in detail in Annex 4.

6.2.Environmental impact

6.2.1.Final energy savings

[Figure 5](#_Ref509222919)
 shows the EU final energy (i.e. electricity) consumption of light sources for the different policy options. This includes energy consumption by control gears. The projected savings for the different scenarios vs. the baseline are given in 
[Table 8](#_Ref509393832)
.

The baseline already shows decreasing energy use. This reflects the continuing effect of existing regulations and the general trend in the market, which anyway includes a gradual shift to higher efficient LED products. Relative to 2015 the reductions are 16 TWh/a (-4.8 %) in 2020, 24 TWh/a (-7.1 %) in 2025, and 37 TWh/a (-11 %) in 2030.

In the other options, compared to the baseline, additional energy savings are obtained, due to the increase in average LED efficacy (labelling), and due to the accelerated shift to LED products (ecodesign). The annual savings increase with the years, as the installed stock of light sources is gradually being replaced by more efficient models.

In the ELOnly option (labelling only) savings vs. the baseline in 2030 are 11.5 TWh/a (-3.8%). 11.5 TWh/y is almost equivalent to the total final electricity consumption of Slovenia in 2015. Adding the ecodesign measures, the savings increase to 41.9 TWh/a (-14.0%) for ECOEL2021 and to 40.1 TWh/a (-13.4%) for ECOEL2tiers. The difference between the two Ecodesign options is the effect of the two year postponement of the phase-out of T8 linear fluorescent lamps. The labelling measures represent 21% of the total energy savings in 2030 from energy label and ecodesign combined together (40-42 TWh/y depending on the Ecodesign option).

Cumulative over the period up to 2030, the highest energy savings are obtained in the ECOEL2021 option: 267 TWh or 7.1% less than in the baseline.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48011.jpg)

Figure 5: EU final energy consumption by light sources over the period 2005-2030, in TWh/a electricity, for various scenarios (Impact assessment study 2018)

Table 8: Total EU Final Energy (Electricity) for lighting in TWh annual or cumulative. Absolute value for the baseline (BAU) and savings vs. BAU for the other scenarios. (Impact Assessment Study 2018)

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Final Energy  (Electricity) (TWh) | | 2015 | 2020 | 2025 | 2030 | Cumulative 2019-2030 |
| Baseline (BAU) | Electricity | 336 | 320 | 312 | 299 | 3745 |
| EL2021 | saving |  | 0.0 | -4.2  (-1.3%) | -11.5  (-3.8%) | -54  (-1.4%) |
| ECOEL2021 | Saving |  | -2.0 | -26.3  (-8.4%) | -41.9  (-14.0%) | -267  (-7.1%) |
| ECOEL2tiers | Saving |  | -0.8 | -20.1  (-6.4%) | -40.1  (-13.4%) | -220  (-5.9%) |

(includes control gear energy; excludes electricity consumption by controls, special purpose lamps and standby)

6.2.2.GHG-emissions

[Figure 6](#_Ref510970611)
 shows the EU GHG-emissions due to lighting for the different policy options. As these emissions are those occurring during electricity generation, the trends are similar to those for energy consumption presented above. The main difference is that for the energy scenarios, by convention, a primary energy factor
[77](#footnote77)
 of 2.5 (according the Annex V of the Energy Efficiency Directive (Directive 2012/27/EU
[78](#footnote78)
) is used, whereas for the projections of the GHG-emissions changes in carbon-intensity of electric power generation are taken into account.

The emission reduction in the baseline relative to 2015 thus reflects the energy savings in the same scenario: 11 MtCO2eq./a (8 %) in 2020, 21 MtCO2eq./a (16 %) in 2025, and 31 MtCO2eq./a (23 %) in 2030. The GHG emission savings projected for the different scenarios are given in Table 15.

Similar to the energy savings, the largest reduction of emissions is obtained in the ECOEL2021 scenario: 14.3 MtCO2eq./a less than in the baseline in 2030 (-14%). Cumulative over the period up to 2030 the savings amount to 94 MtCO2eq. (-6.9%).

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48012.jpg)

Figure 6: EU Greenhouse gas emissions due to use of light sources and control gears, over the period 2015-2030, in Mt CO2 equivalent per year, for various scenarios

Table 9: Overview of GHG emissions due to electricity consumption by light sources and control gears. Absolute value for the baseline (BAU) and savings vs. BAU for the other scenarios. (Impact Assessment Study 2018)

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| GHG emissions  (MtCO2 equivalent) | | 2015 | 2020 | 2025 | 2030 | Cumulative 2019-2030 |
| Baseline (BAU) | Electricity | 133 | 122 | 112 | 102 | 1356 |
| EL2021 | saving |  | 0.0 | -1.5 | -3.9 | -19 |
| ECOEL2021 | Saving |  | -0.7 | -9.5 | -14.3 | -94 |
| ECOEL2tiers | Saving |  | -0.3 | -7.2 | -13.6 | -77 |

 

6.2.3.Circular Economy perspective

The environmental life-cycle assessments in the Review Study 2015 show that the energy consumption and the related emissions are by far the dominant environmental impacts for this product category.

For material resources efficiency, all options, except the baseline option, introduce clear requirements to address the phenomenon of fully integrated luminaires as explained in Section 2.3 and Section 5.2.2. As for energy labelling, luminaires with non-dismountable light sources will be considered as light sources for the purposes of the energy labelling legislation and will be required to have an energy label. As for ecodesign, in the two options that have ecodesign measures (Options 3 ECOEL21 and 4 ECOEL2tiers), luminaires with non-dismountable light sources will be considered a light source for the purposes of the ecodesign legislation and will need to satisfy the ecodesign requirements.

The aim of the proposed requirements is to stimulate manufacturers to find innovative solutions and design for dismountable luminaires using LEDs. Better design can make products more durable or easier to repair, upgrade or remanufacture. It can help recyclers to disassemble products in order to recover valuable materials and components. Overall, it saves resources. The current market signals appear insufficient to make this happen, in particular because the interests of producers, users and recyclers are not aligned. In addition, reparability can be important to consumers. It is therefore essential to provide incentives for improved product design, while preserving the single market and competition, and enabling innovation through ecodesign.

The proposed requirements address the problem of non-dismountable luminaires in an indirect way. In 2017 the Commission checked the possibility to have mandatory removability of light sources from luminaires, but there are technological drawbacks. Many luminaires are manufactured so that LED light sources are tightly mechanically integrated to optimise thermal management and for protection purposes. The side effect of this technology solution is that the unsealing and resealing of LED lights in the luminaire may hamper their energy efficiency. A way forward would be to include a review clause in the legislative proposal to investigate mandatory removability of light sources from luminaires, which will impact recyclability as well.

Even though the Circular Economy dimension is not directly addressed, the proposed requirements for non-dismountable luminaires are in the spirit to promote circular economy because they will: (i) resolve the problem that market surveillance authorities have to test light sources when these are not accessible; (ii) resolve the issue of an unfair level playing field for industry when the same light source type is accessible; and (iii) support consumers in their conscious choice when buying integrated luminaires.

As for recyclability, this impact assessment does not explore measures for the recyclability of lighting products because lighting products are already in scope of Directive 2012/19/EU on waste of electric and electronic equipment
[79](#footnote79)
 (WEEE).The WEEE Directive introduced in August 2018 new recovery and recycling targets, including for lighting products. Until 14 August 2018 the lighting equipment in scope of the WEEE Directive includes all lamps, with the exception of filament bulbs, and all luminaires, with the exception of luminaires in households (Annex II of the WEEE Directive, Category 5). From 15 August 2018 the scope is enlarged to all luminaires, with specific requirements for large and small luminaires (Annex III of the WEEE Directive, Categories 4 and 5).Because of the close date of application of the new WEEE target for lighting products, it is deemed more relevant to look into requirements that would complement the WEEE directive in the next review of the ecodesign legislation.

The producers of the lighting equipment in scope of the WEEE Directive are in charge of meeting recycling and recovery targets that increase over time:

·Until 14 August 2018:

•75 % shall be recovered, and 55 % shall be prepared for reuse and recycled (for gas discharge lamps, 80 % shall be recycled);

·From 15 August 2018:

•for lamps (category 3): 80 % shall be recycled;

•for large luminaires (category 4): 85 % shall be recovered, and 80% shall be prepared for reuse and recycled;

•for small luminaires (category 5): 75 % shall be recovered, and 55% shall be prepared for reuse and recycled.

Currently the lighting equipment in scope of the WEEE Directive represents 5% of the total electrical and electronic equipment placed on the EU28 market annually and 2% of the total WEEE collected and recycled annually.

6.3.Business impacts

6.3.1.Business revenue

Business
[80](#footnote80)
 revenues mainly depend on the quantity of products being sold and on their average price. For light sources there is a complex interaction between factors that increase and decrease the revenues:

-There is a tendency for the number of installed light sources to increase with the years (more households, more light sources per household, increasing GDP). This potentially indicates an increase in sales quantities.

-However, at the same time the average lifetime of light sources is increasing. This implies a lower need to buy replacement lamps and thus a decrease in sales. At least for the next 10 years, this decrease is stronger than the increase deriving from the general growth of the previous point. Hence on the short-medium term, sales quantities of light sources are going down.

-Energy savings and GHG emission reductions for light sources are obtained by a shift from traditional lighting technologies to LEDs with higher energy efficiency. For the same light output, these LEDs have higher acquisition costs (but lower electricity costs) than the traditional lamps. So the shift to LEDs potentially implies a higher average sales price per lamp.

-Due to the learning effect and the exponential increase in the quantities of LEDs being sold, their price is rapidly coming down and this trend is expected to continue in the BAU scenario (Option 1).

-However, the proposed regulation aims at increasing the average efficacy of LEDs being sold, and these high-efficient LEDs have a higher sales price.

The assumptions made in the analysis model regarding the development of the sales quantities and of the average unit prices are reported in detail in Annex 4. They lead to the business revenues shown in 
[Table 10](#_Ref509228760)
. 
[Figure 7](#_Ref509229751)
 shows the projected industry revenue for the different policy options.

In the baseline option, business revenues show a decreasing trend due to the decrease in sales quantities. In ten years, from 2015 to 2025, total business revenues from light sources decrease from EUR 21.6 to 17.0 billion per year (-21%). In the same period, industry revenues decrease from EUR 9.7 to 6.3 billion per year (-35%). Towards 2030, revenues slightly increase again due to the general growth in the number of light sources (first point above).

The effect of Option 2 – ELOnly is an increase in the average efficacy of LED products being sold (pull-effect of labelling). Starting from 2021, compared with the baseline, this increases the average price per light source and thus increases total business revenues by 9-11% in 2025 and 2030 relative to the baseline scenario.

The same effect of improved labelling is also present in Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers, but additionally the introduced Ecodesign measures increase the number of LED light sources being sold, by phasing-out from the market some traditional lamp types. This situation further increases business revenues due to an increase in sales quantities, with anticipatory effects from 2019
[81](#footnote81)
. Different from the labelling effect, this increased-sales effect is temporary: instead of a gradual shift to LEDs in the base line, the Ecodesign measures accelerate the LED sales in earlier years, but then lead to lower sales of LEDs in later years.

In Option 3 – ECOEL2021 this leads to higher total business revenues especially in early years, with, respect to Option 2 – ELOnly, a 5% increase in 2020, 9% increase in 2025, and a 2% decrease in 2030. Considering only industry revenues, the increase is 10% in 2020, 18% in 2025, and zero in 2030.

In Option 4 – ECOEL2tiers, the phase-out of T8 linear fluorescent tubes is postponed from 2021 to 2023, and consequently also the associated increased sales of LEDs and the corresponding increase in business revenues shift forward by two years. Increases in business revenues in Option 4 are therefore much smaller than those in Option 3 in 2020, but higher in 2025 and 2030.

Cumulatively over the period up to 2030, increases in revenues have the highest value for Option 3 – ECOEL2021: EUR 29 billion (+13%). The same explanation also applies to associated jobs, which are directly related to revenues (see Section 6.5.3).

Table 10: Overview business revenue per sector
[82](#footnote82)
 and per scenario, in billion EUR [2010] in the EU

(Impact Assessment Study 2018).

|  |  |  |  |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| bn EUR |  | INDUSTRY | | | | WHOLESALE&RETAIL | | | | INSTALLATION | | | |
|  |  | 2015 | 2020 | 2025 | 2030 | 2015 | 2020 | 2025 | 2030 | 2015 | 2020 | 2025 | 2030 |
| Baseline | revenue | 9.7 | 9.3 | 6.3 | 6.4 | 4.0 | 2.9 | 1.8 | 1.7 | 3.0 | 3.1 | 2.6 | 2.5 |
| EL2021 | variation |  | 0 | +1.3 | +1.2 |  | 0 | +0.3 | +0.3 |  | 0 | 0 | 0 |
| ECOEL2021 | variation |  | +0.9 | +2.7 | +1.2 |  | +0.2 | +0.5 | +0.2 |  | 0 | -0.1 | -0.2 |
| ECOEL2tiers | variation |  | +0.2 | +2.8 | +1.5 |  | 0 | +0.5 | +0.3 |  | 0 | -0.1 | -0.1 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |  |
|  |  | MAINTENANCE | | | | TOTAL | | | | | | | |
|  |  | 2015 | 2020 | 2025 | 2030 | 2015 | 2020 | 2025 | 2030 | Cumulative 2019-2030 | | | |
| Baseline | revenue | 5.0 | 5.6 | 6.3 | 7.2 | 21.6 | 20.9 | 17.0 | 17.8 | 221 | | | |
| EL2021 | variation |  | 0 | 0 | 0 |  | 0 | +1.6 | +1.4 | +14 | | | |
| ECOEL2021 | variation |  | 0 | 0 | 0 |  | +1.1 | +3.2 | +1.1 | +29 | | | |
| ECOEL2tiers | variation |  | 0 | 0 | 0 |  | +0.1 | +3.4 | +1.7 | +26 | | | |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48013.jpg)

Figure 7: Projected EU industry revenue over the period 2015-2030, in bn EUR/y, for various scenarios

(Impact assessment study 2018)

6.3.2.Innovation, Research and Development, Competitiveness

The revision of the lighting energy labelling regulation is expected to support innovation and drive market transformation, as was observed in the past. It is in line with ongoing market trends towards higher energy efficiency, where a high energy label rating is a strong commercial driver (Review Study 2016).

All LED technologies are today in the three top energy labelling classes. A new labelling scale based on the re-scaling required in the new energy labelling framework regulation will stimulate innovation to develop LEDs that will reach the new top classes.

The development of innovative energy-efficient technologies at competitive prices
[83](#footnote83)
 will enhance the competitiveness of European manufacturers. This is important because Asian manufacturers are rapidly expanding their global market share. For these manufacturers, product price, rather than quality, is one of the main selling points.

6.3.3.Intellectual Property Rights

The technologies considered in all scenarios are commonly available to all major manufacturers.

6.4.Consumer expenditure

Consumer expenditure consists of acquisition costs (purchase and installation), maintenance costs and electricity costs. Maintenance costs are assumed not to change between the options. The options different from the baseline promote a shift to LEDs and this causes additional acquisition costs in early years. This initial investment made by users is gradually paid back in later years through lower electricity costs. The acquisition cost, energy cost and overall consumer expenditure for the different scenarios are shown in 
[Table 11](#_Ref512705572)
 and 
[Figure 8](#_Ref510970635)

[84](#footnote84)
. Table 11 shows that the overall effect in 2030 for consumers when considering acquisition costs and electricity costs is positive for all options. See Annex 4 for further details.

Option 3 – ECOEL2021 requires the highest investment in LED products, concentrated in earlier years, cumulative EUR +30 billion (+20%) vs. Option 1 – BAU over the period up to 2030. However, the same option also leads to the highest energy cost savings, increasing in later years, cumulative EUR -52 billion (-7.8%) vs. Option 1 – BAU, and therefore has the highest user expense savings, cumulative EUR -21 billion (-2.4%).

Table 11: Total EU Acquisition costs, Electricity Costs, Maintenance Costs and Total User Expense for light sources, in billion EUR/y or billion EUR cumulative over the period 2019-2030. Totals for the BAU-scenario and savings vs. BAU for the other scenarios. Costs in fixed 2010 EUR, incl. VAT for residential. Negative numbers are saving; positive numbers additional expense. (Impact Assessment Study 2018)

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Acquisition (bn EUR) | | 2015 | 2020 | 2025 | 2030 | Cumulative  2019-2030 |
| BAU | Absolute | 17.9 | 16.1 | 10.9 | 10.8 | 150 |
| EL2021 | saving |  | 0.0 | +1.7 | +1.5 | +15 |
| ECOEL2021 | saving |  | +1.1 | +3.3 | +1.2 | +30 |
| ECOEL2tiers | saving |  | +0.1 | +3.4 | +1.7 | +27 |
| Electricity (bn EUR) | | 2015 | 2020 | 2025 | 2030 | Cumulative |
| BAU | Absolute | 47.5 | 48.3 | 56.0 | 65.0 | 666 |
| EL2021 | saving |  | 0.0 | -0.8 | -2.6 | -11 |
| ECOEL2021 | saving |  | -0.3 | -4.8 | -8.9 | -52 |
| ECOEL2tiers | saving |  | -0.1 | -3.8 | -8.5 | -44 |
| Maintenance (bn EUR) | | 2015 | 2020 | 2025 | 2030 | Cumulative |
| ALL scenarios | Absolute | 5.0 | 5.6 | 6.3 | 7.2 | 76 |
| Expense (bn EUR) | | 2015 | 2020 | 2025 | 2030 | Cumulative |
| BAU | Absolute | 70.4 | 70.0 | 73.3 | 83.0 | 891 |
| EL2021 | saving |  | 0.0 | +0.9 | -1.1 | +4 |
| ECOEL2021 | saving |  | +0.8 | -1.5 | -7.7 | -21 |
| ECOEL2tiers | saving |  | 0.0 | -0.3 | -6.8 | -17 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48014.jpg)

Figure 8: Projected consumer expenditure over the period 2015-2030, in billion EUR [2010] per year

(Impact Assessment Study 2018)

6.5.Administrative burden

The administrative burden for industry and MSAs is an area that could be improved in the current legislation, as explained in Section 2.2. With the new regulations proposed in Options 2 – EL2021, 3 – ECOEL2021 and 4 – ECOEL2tiers, the total administrative burden will decrease, especially for European SMEs.

Indeed, Options 2 – EL2021, 3 – ECOEL2021 and 4 – ECOEL2tiers propose the abolition of the energy label applicable to luminaires. This measure will save costs and reduce burden for luminaires’ suppliers – 90% of which are SMEs. The burden will be reduced because of the fact that SMEs will not need to prepare the label and ensure its conformity, also in view of possible surveillance by market authorities.

[85](#footnote85)
[86](#footnote86)
[87](#footnote87)
The reduced burden will come not only from the abolition of the label but also from the abolition of the obligation to insert data in the products database EPREL introduced by the Energy Labelling Framework Regulation (EU) 2017/1369. Between 1 million and 3 million model luminaires are estimated to need a label today. Based on Eurostat data for year 2016, around 250 million luminaires are sold each year in EU28. With the revised energy labelling, only the fully integrated luminaires would be assimilated to light sources and thus added to the list of light sources that need to have an energy label. It is estimated that savings for SMEs will be at least EUR 35 million. Moreover, increased turnover should also be considered.

In addition, the simplification of tests in Options 3 and 4 will reduce the number of tests and eliminate tests that lost relevance by time. The impact on the industry from the new tests for LEDs is estimated to be negligible because the existing testing appliances are set or can be easily set to run the new tests. The same is valid for MSAs (see in Section 7.2).

[88](#footnote88)
Conversely, the rescaling of the label of products on the market as required by the Energy Labelling Framework Regulation (EU) 2017/1369 would bring new costs in Options 2 – EL2021, 3 – ECOEL2021 and 4 – ECOEL2tiers. It is estimated that suppliers and dealers will encounter extra costs of respectively EUR 30 million and EUR 4 million. Suppliers will need to provide a second label for the products to rescale for each light source that will stay on the shelves of dealers after nine months (an estimated 10% of products), while dealers will need to relabel with stickers and 2.5 % of their products on display.

6.6.Social Impact

6.6.1.Affordability

To obtain the energy savings and reduction of GHG emissions, users have to invest in more, and more efficient, LED lighting products. Compared to the baseline, this leads to additional acquisition costs (see Section 6.3). For the EU as a whole, for the ELOnly option these are maximum 1.8 billion EUR/y in 2026 (EUR 3.6 per citizen; +17% vs baseline in that year). For the ECOEL2021 option the maximum is EUR 4.2 billion per year in 2022 (EUR 8.4/citizen; +31%), and for the ECOEL2tiers option EUR 3.7 billion per year in 2024 (EUR 7.4/citizen; +32%). See also the graphs at the end of Annex 4.

This investment is payed back in later years in terms of lower electricity costs, leading to the total user expense savings reported in Section 6.3. On average, payback times are around 1 year or less for low-output residential lamps, and around 3-4 years for higher-output LED tubes replacing T8 linear fluorescent lamps
[89](#footnote89)
.

On the other hand, both options that would introduce new requirements for ecodesign (Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers) do not change the requirements for LFL T5, HPS and MH that exist today: consequently, nothing changes for the users of these lamps. The reason for this choice is that many non-residential lighting users recently invested in luminaires for higher efficiency T5 linear fluorescent lamps (LFL T5), or for sodium or metal-halide lamps (HPS, MH), to replace lamp types that were phased-out by existing regulations. It would not be acceptable to force these users to change again before they have amortised their previous investments. In addition, LED replacement lamps (also known as “LED retrofit lamps”) for these classical lamp types are scarce so that users would often be forced to substitute entire luminaires.

Stakeholders view – In relation to the phase-out of T8 linear fluorescent lamps, some stakeholders argued that for organisations managing large quantities of such lamps, the investment to make in LEDs would be too high to bear in such a short time. This is a misunderstanding of the intention of the regulation, i.e. there is no obligation to replace all installed LFL T8 by LED before the date set in the regulation: lamps can gradually be replaced when they fail, over a much longer period, thus spreading out the costs.

6.6.2.Health, Safety and Functionality Aspects

LEDs are sometimes criticised to have flicker or stroboscopic problems
[90](#footnote90)
, colour inconsistency or bad colour rendering. Especially the problem of flicker has been confirmed for many lamps during screening testing carried by the EU-funded project EEPLIANT which was finalised in 2017
[91](#footnote91)
. Following comments at the Consultation Forum
[92](#footnote92)
 and from the online public consultation that ran until 7/5/2018
[93](#footnote93)
, Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers include functional requirements for flicker and stroboscopic effects for LEDs
[94](#footnote94)
 to improve the quality of LEDs on the market.

Some stakeholders have raised functionality concerns as regards e.g. colour tuneable lamps and some special purpose applications, including lighting in railways and studio, theatre and stage lighting. These comments have been taken into account for the formulation of exemptions in the ecodesign measures in Options 3 and 4.

It is also considered to introduce mandatory information on the date of production of light sources and control gears, wherever they are contained. Manufacturers are required to indicate the expected lifetime of the product, also following a high favour from respondents to the online public consultation (72% - see Annex 2).

Finally, it is considered to introduce an exemption for the purchase of incandescent lamps with medical prescription for people that are photosensitive to LEDs, to meet their health concerns (despite studies found no significant or safety hazard from using LEDs
[95](#footnote95)
).

Stakeholders view – Many stakeholders, especially Member States, consumers and their associations, welcomed the idea of a requirement to tackle the flicker effect
[96](#footnote96)
 and asked to think of a requirement for stroboscopic effect. Some consumers are concerned that LEDs emit more UV-radiation or have other potential health risks from blue light.. Stakeholders from the theatre/stage/studio sector would like to keep a full exemption for lighting used in their sector: however many comments assumed that at the date of application of the new legislation, theatres and similar would need to replace all lamps and luminaires (which is not true, because ecodesign and energy labelling only apply to the placing on the market of new products and not to products in use or in stock).

6.6.3.Employment

In the baseline scenario, the global jobs related to the EU light source business are projected to decrease from 314 000 in 2015 to 243 000 (-23%) in 2030. This follows the decreasing trend in sales and in business revenues discussed in Section 6.2. The decrease in jobs is mainly in EU28 industry, due to lower production of incandescent-, halogen- and fluorescent-lamps. Jobs in retail and installation decrease due to lower sales volumes, while jobs in maintenance increase due to the increase in number of light source in use.

The other scenarios accelerate the shift to high-efficacy LED products, leading to an increase in jobs worldwide. This partly avoids the loss of jobs that occurs in the baseline. The positive effect on wholesale and retail is inside EU28. A large part of the increase in industry jobs is outside EU28: the production of basic LED components is mainly done in Asia. The additional jobs in EU industry regard e.g. machinery for the production of LED components, the integration of LED components (dies, packages, modules) into higher level products (lamps, light engines, luminaires), development of new applications (smart lighting, network connected lamps, colour-tuneable devices, human-centric lighting), research and development for increase of efficacy and quality, involving also new optical and thermal solutions.

In Option 3 – EL2021 the increase in jobs is gradual and due only to an increase in LED efficacy that brings an increase in the production of LEDs of higher quality than in the baseline scenario. In addition to the label effects, the LED sales increase in early years, leading to more jobs especially in 2020-2025. This effect vanishes by 2030.

In Option 4 – ECOEL2tiers the phase-out of T8 linear fluorescent lamps is postponed by two years, and consequently also the increase in LED sales and the associated increase in jobs shift forward in time. This leads to additional jobs especially in 2025-2030.

[Table 12](#_Ref509242525)
 gives an overview of the employment impact worldwide due to EU light source business. Jobs related to the sale and installation of luminaires are not included.

The analysis takes into account only jobs in the supply chain: induced employment from spending of e.g. employees’ earnings or tax revenues, is not included. A large share (estimated 60-70%) of the industry jobs, especially those related to LED light sources, is outside the EU28. Jobs for wholesale, retail, installation and maintenance are assumed to be all inside the EU28.

Table 12: Overview of direct employment per sector and per scenario, in ‘000 jobs

(Impact Assessment Study 2018)

|  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| sector | INDUSTRY | | | | | | | WHOLESALE | | | | | | | | RETAIL | | | | | | INSTALLATION | | | | |
| scenario | 2015 | | 2020 | | 2025 | 2030 | | | 2015 | | 2020 | | 2025 | | 2030 | | 2015 | 2020 | | 2025 | 2030 | | 2015 | 2020 | 2025 | 2030 |
| Baseline | 194 | | 186 | | 126 | 129 | | | 8 | | 6 | | 4 | | 3 | | 31 | 23 | | 14 | 14 | | 30 | 31 | 26 | 25 |
| ELOnly |  | | 186 | | 151 | 151 | | |  | | 6 | | 4 | | 4 | |  | 23 | | 17 | 16 | |  | 31 | 26 | 25 |
| ECOEL2021 |  | | 205 | | 180 | 151 | | |  | | 6 | | 5 | | 4 | |  | 24 | | 19 | 16 | |  | 31 | 25 | 23 |
| ECOEL2tiers |  | | 189 | | 182 | 159 | | |  | | 6 | | 5 | | 4 | |  | 23 | | 19 | 16 | |  | 31 | 25 | 24 |
|  | | | | | | | | | | | | | | | | | | | | | | | | | | | |
| sector | MAINTENANCE | | | | | | | TOTAL | | | | | | | | Increase | | |
| scenario | 2015 | 2020 | | 2025 | | | 2030 | 2015 | | 2020 | | 2025 | | 2030 | | 2030 | | |
| Baseline | 50 | 56 | | 63 | | | 72 | 314 | | 302 | | 234 | | 243 | | Ref | | |
| EL2021 |  | 56 | | 63 | | | 72 |  | | 302 | | 262 | | 269 | | +26 | | |
| ECOEL2021 |  | 56 | | 63 | | | 72 |  | | 322 | | 293 | | 266 | | +23 | | |
| ECOEL2tiers |  | 56 | | 63 | | | 72 |  | | 304 | | 295 | | 275 | | +32 | | |

 

The worldwide impact on employment is estimated from the variations in EU light source business revenue, using a sector-dependent turnover per employee
[97](#footnote97)
. Consequently, projections for jobs closely follow the projections in business revenues that were explained in Section 6.2.1. Similarly, these revenues are closely related to the acquisition costs for users, see 
[Figure 9](#_Ref512616162)
. For further details on employment see Annex 6.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_48015.jpg)

Figure 9: EU Acquisition costs for light sources over the period 2015-2030, in billion EUR [2010] per year. Business revenues for industry, wholesale and trade closely follow these projections.

(Impact Assessment Study 2018)

7.How do the options compare?

7.1.Summary of the impacts

Table 13 summarizes the impacts described in Section 6.

Option 2 – ELOnly option has the lowest additional acquisition costs and maintains installer revenues at the same level as the baseline, but energy savings, emission reductions and user expenditure savings are much smaller than in the other two options.

Option 3 – ECOEL2021 option offers the highest electricity savings and the highest reduction of GHG-emissions. It requires higher acquisition costs especially in earlier years (user investment in high efficiency LED products), but this is more than compensated by lower energy costs in later years, so that this option leads to the highest savings on total user expenditure. In general this option also entails the highest business revenues and the best preservation of jobs, concentrated in earlier years.

Option 4 – ECOEL2tiers option is similar to Option 3 – ECOEL2021 but with the phase out of the fluorescent T8 lamps delayed in time. Due to this delay, it leads to lower energy savings, lower reduction in emissions, and lower user expense savings. The option seems preferable for business revenues and jobs in 2025 and 2030, but this is due to the shift in time: cumulatively over the period up to 2030 Option 3 is more favourable.

Table 13: Overview of the main annual impacts of the options compared to the baseline. Absolute values for the baseline and variations for the optional scenarios (negative values are savings or reductions; positive values are additional costs, revenues or jobs). Annual values for 2015, 2020, 2025 and 2030; cumulative values over the 2015-2030 period. Best values indicated in Bold. (Impact Assessment Study 2018)

|  |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  |  | 2015 | 2020 Annual | | | | 2025 Annual | | | |
|  | Unit | BAU absolute | BAU absolute | EL  2021 | ECOEL  2021 | ECOEL  2tiers | BAU absolute | EL  2021 | ECOEL  2021 | ECOEL  2tiers |
| Electricity use | TWh | 336 | 320 | 0.0 | -2.0 | -0.8 | 312 | -4.2 | -26.3 | -20.1 |
| GHG emissions | MtCO2eq | 133 | 122 | 0.0 | -0.7 | -0.3 | 112 | -1.5 | -9.5 | -7.2 |
| Acquisition costs | bn. EUR | 18 | 16 | 0.0 | +1.1 | +0.1 | 11 | +1.7 | +3.3 | +3.4 |
| Energy costs | bn. EUR | 48 | 48 | 0.0 | -0.3 | -0.1 | 56 | -0.8 | -4.8 | -3.8 |
| Expenditure1 | bn. EUR | 70 | 70 | 0.0 | +0.8 | 0.0 | 73 | +0.9 | -1.5 | -0.3 |
| Industry revenue | bn. EUR | 10 | 9 | 0.0 | +0.9 | +0.1 | 6 | +1.2 | +2.7 | +2.8 |
| Trade revenue | bn. EUR | 4 | 3 | 0.0 | +0.2 | 0.0 | 2 | +0.3 | +0.5 | +0.6 |
| Installer revenue | bn. EUR | 3 | 3 | 0.0 | 0.0 | 0.0 | 3 | 0.0 | -0.1 | -0.1 |
| Employment | 000 jobs | 314 | 302 | 0.0 | +20.3 | +2.5 | 234 | +28.2 | +58.9 | +61.6 |
|  | | | | | | | | | | |
|  |  |  | 2030 Annual | | | | 2015-2030 Cumulative 2 | | | |
|  | Unit |  | BAU absolute | EL  2021 | ECOEL  2021 | ECOEL  2tiers | BAU absolute | EL  2021 | ECOEL  2021 | ECOEL  2tiers |
| Electricity use | TWh |  | 299 | -11.5 | -41.9 | -40.1 | 5079 | -54 | -267 | -220 |
| GHG emissions | MtCO2eq |  | 102 | -3.9 | -14.3 | -13.6 | 1878 | -19 | -94 | -77 |
| Acquisition costs | bn. EUR |  | 11 | +1.5 | +1.2 | +1.7 | 222 | +15 | +30 | +27 |
| Energy costs | bn. EUR |  | 65 | -2.6 | -8.9 | -8.5 | 853 | -11 | -51 | -43 |
| Expenditure | bn. EUR |  | 83 | -1.1 | -7.7 | -6.8 | 1171 | +4 | -21 | -17 |
| Industry revenue | bn. EUR |  | 6 | +1.1 | +1.1 | +1.5 | 127 | +11 | +25 | +22 |
| Trade revenue | bn. EUR |  | 2 | +0.3 | +0.2 | +0.3 | 40 | +3 | +5 | +4 |
| Installer revenue | bn. EUR |  | 3 | 0.0 | -0.3 | -0.2 | 45 | 0 | -1 | -1 |
| Employment | 000 jobs |  | 243 | +25.6 | +22.6 | +31.8 |  |  |  |  |
| 1 Expenditure = Acquisition Cost + Energy Cost + Maintenance Cost, latter not shown in table  2 The variations due to measures in general occur from 2021, but for the Ecodesign measures there are anticipatory effects starting from 2019 | | | | | | | | | | |

7.2.Market Surveillance

All proposed policy options would be subject to Article 15(8) of the Ecodesign Framework Directive, as well as Article 8(1) and (3) of Energy Labelling Framework Regulation, which require that MSAs can verify the conformity of a product with all regulatory requirements.

The burden for MSAs to assess compliance is significantly reduced by the new proposals, as explained in the previous chapters. However, this would not mean a monetary saving from reduced administrative burden for MSAs: MSAs would spend the freed-up time on other market surveillance activities instead, thereby contributing to higher compliance rates for the overall ecodesign and energy labelling policy
[98](#footnote98)
.

As for the new verification tests that the proposals introduce, MSAs either have their own facilities for testing or rely on expert laboratories. In both cases, the new tests do not put extra burden on MSAs as the existing testing appliances are set or can be easily set to run the new tests. Stakeholders have emphasised the importance of securing a sufficient level of market surveillance to ensure that only compliant products are placed on the market. In this respect, they call for increased enforcement by MSAs.

7.3.Assessment in view of Article 15(5) of the Ecodesign Framework Directive and Article 16 (2) of the Energy Labelling Regulation 

Pursuant to Article 15(5) of the Ecodesign Framework Directive, future implementing measures should fulfil a number of criteria, see Section 3.1. An assessment of the options in view of these criteria is shown in 
[Table 14](#_Ref509394261)
.

Table 14: Evaluation of policy options in terms of their impacts compared to the baseline

(Impact Assessment Study 2018)

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Significant impacts as stipulated in Article 15 of the Ecodesign Directive | BAU | EL  2021 | ECO  EL  2021 | ECO  EL 2tiers |
| No negative impacts on the functionality (Section 6.6) | ✓ | ✓ | ✓ | ✓ |
| No negative impacts on health, safety and environment (Section 6.6) | ✓ | ✓ | ✓ | ✓ |
| No negative impact on consumers (Section 6.4 and 6.6) | ✓ | ✓ | ✓ | ✓ |
| No negative impacts on industry's competitiveness (Sections 6.3) | ✓ | ✓ | ✓ | ✓ |
| Not imposing proprietary technology (Section 6.3) | ✓ | ✓ | ✓ | ✓ |
| No excessive administrative burden on manufacturers (Section 6.5) | ✓ | ✓ | ✓ | ✓ |

All options fulfil the criteria of Article 15(5).

Pursuant to Article 16(2) of the Energy labelling Framework Regulation, future implementing measures should fulfil a number of criteria, see Section 3.1. The criteria are fulfilled, namely:

§The product group has significant potential for saving energy (See Figure 5: at 2030 the savings are equivalent to the electricity consumption of Slovenia in 2015);

§The proposed bands of the energy label will differentiate among LEDs, which are today all concentrated in the top classes;

§No negative impact on affordability, as shown in Section 6.5.1 and Table 11;

§Additional functionality requirements, to improve the quality of products.

All options with the new energy label (Option 2 EL2021, Option 3 ECOEL2021 and Option 4 ECOEL2tiers) fulfil the criteria of Article 16(2).

7.4.Assessment in view of the objectives

An assessment of the options, in view the objectives in Section 4, is shown in 
[Table](#_Ref494116395)
[15](#_Ref494116395)
, on the basis of

[Table 13](#_Ref509308843)
 and Table 14.

Table 15: Score of impacts against objectives. No Change (0), limited improvement (+), significant improvement (++). (Impact Assessment Study 2018)

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| General Objectives | Option baseline | Option ELOnly | Option ECOEL2021 | Option ECOEL2tiers |
| 1. Ensure free circulation of efficient products within the internal market; | 0 | + | + | + |
| 2. Promote competitiveness of the lighting industry through the creation or expansion of the EU internal market for sustainable products;\* | 0 | + | + | + |
| 3. Promote the energy efficiency of lighting products as contribution to the Commission's objective to reduce energy consumption by 30 % and domestic GHG emissions by 40 % by 2030; | 0 | + | ++ | + |
| 4. Increase the security of energy supply in the Union through a reduction in energy consumption of lighting products. | 0 | + | + | + |
| Specific Objectives |  |  |  |  |
| 1. Update the energy efficiency requirements and the energy label in line with international and technical developments; | 0 | 0/+ | ++ | + |
| 2. Redefine the scope and the exemptions to reduce the administrative burden and close loopholes | 0 | + | + | + |
| 3. Contribute towards a circular economy in the EU by including requirements for non-dismountable products containing light sources | 0 | + | + | + |

\*Innovation will enhance competitiveness of the EU manufacturers; the effect on innovation is therefore included in this objective.

Option 1 – BAU does not contribute to any of the objectives. The other options contribute to the general objectives. Option 2 – ECOELOnly only contributes fully to two out of three specific objectives: it is therefore not seen as the preferred policy option. Option 3 – ECOEL2021 and Option 4 – ECOEL2tiers positively contribute to all objectives in the same way, except for the contribution to the EU 2030 goals and the specific objective ‘Update the energy efficiency requirements and the energy label in line with international and technical developments’. Here Option 3 performs best thanks to the earlier time of application of the new measures. As a consequence Option 3 – ECOEL2021 is the preferred option. More information on the benefits of Option 3 is included in the next section.

8.Preferred option

8.1.Preferred option – Why?

Option 3 – Ecodesign and Energy label at 2021 ("ECOEL2021") fulfils the criteria in Article 15(5) of the Ecodesign Regulation and Article 16(2) of the Energy Labelling Regulation, see Section 3.1, and will achieve the objectives as set out in Section 4 in the best way, see Section 5.2.3.

By 2030, compared to Option 1 – BAU, Option 3 will result in the following:

·Extra energy savings of 41.9 TWh/yr and GHG emission savings of 14.3 MtCO2eq./a, i.e. 2.88% of the Commission’s 2030 target for final energy consumption savings and 1.34 % of the Commission’s 2030 target for GHG-emissions savings;

·Extra savings on annual end-user expenditure of EUR 7.7 billion and extra business revenue of EUR 1.1 billion per year, which translates into around 23 000 jobs;

·An alignment with technological progress and global minimum energy efficiency requirements in other economies;

·Ensuring EU industry’s competitiveness and leading role as high-quality manufacturers;

·Safeguarding of European SMEs.

This option promotes innovation and medium-term cost reduction for more efficient lighting products.

8.2.REFIT (simplification and improved efficiency)

This section will describe how the preferred option is expected to improve the efficiency of the existing measures.

Option 3 – ECOEL2021 will reduce the total administrative costs for industry, especially for SMEs manufacturing luminaires following the abolition of the energy label for luminaires. Lighting industry will in general benefit from a simplification of the tests. These measures overcome the one-off cost linked to the application of the new Energy Labelling Framework Regulation which is estimated in EUR 0.34 billion and will not have an impact anymore in 2030 (see Section 6.4).

The burden for MSAs to assess compliance is significantly reduced by the new proposals. It is, however, assumed that MSAs spend the freed-up time on other market surveillance activities, contributing to higher compliance rates: thereby there is no monetary saving from reduced administrative burden for MSAs.

The ECOEL2021 option will also reduce the total consumer expenditure as compared to the baseline. This consumer expenditure includes the acquisition cost and the energy cost. The acquisition cost will be higher, but the energy cost will decrease significantly as compared to the baseline. In addition, this option will improve industry’s revenues significantly.

[Table 16](#_Ref509396610)
 gives an overview of the increment in costs, revenue and administrative burden at 2030 as compared to the baseline.

Table 16: Increment in costs, revenue and administrative burden

|  |  |  |
| --- | --- | --- |
|  | 2030 | Comment |
| Acquisition costs (EUR billion) | 1.2 | The acquisition cost increases, but the total consumer expenditure decreases |
| Energy costs (EUR billion) | -8.9 |  |
| Consumer expenditure (EUR billion) | -7.7 |  |
| Industry revenue (EUR billion) | 1.2 | There is an increase in total business revenue |
| Wholesale and retail revenue (EUR billion)) | 0.2 |  |
| Installation revenue (EUR billion) | -0.2 |  |
| Administrative savings (EUR billion) | 0.001 | Minimum estimated value. The decrease in total administrative burden also stems from freed resources for other activities (for both market surveillance authorities and SMEs) which cannot be easily monetised. See Sections 6.5 and 7.2. |

9.How will actual impacts be monitored and evaluated?

The main monitoring element will be the tests carried out to verify compliance with the ecodesign and energy labelling requirements. This monitoring should be done by Member States’ market surveillance authorities to ensure that requirements are met.

The main indicator for evaluating the impact of potential ecodesign and energy labelling regulations is the achievement of a market improvement towards lighting products with a smaller environmental impact. An analysis of the products on the market (sales figures, performance, etc.) will determine if the shift towards more resource efficient products has happened as estimated, in particular based on the following sub-indicators, which reflect the general and specific objectives:

·Reduction of the electricity consumption and related greenhouse gas emissions from lighting;

·Increasing the economic savings for European consumers;

·Safeguarding the competitiveness of the European lighting industry and the full value chain;

·Improving the regulatory effectiveness and efficiency of the regulation;

·Compliance with energy efficiency requirements
[99](#footnote99)
;

·Compliance with functional requirements;

·Compliance with information requirements;

·Compliance of those products that were potentially excluded due to (i) loopholes or (ii) difficulty in verification.

The evaluation should therefore assess these sub-indicators.

:   [(1)](#footnoteref1)
     Ecodesign requirements are energy efficiency, functional and information requirements.
:   [(2)](#footnoteref2)

     
       
    [Commission Regulation (EC) No 244/2009 of 18 March 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for non-directional household lamps](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523267684326&uri=CELEX:32009R0244)
    , OJ L76/3, 24.3.2009 and amendments Commission Regulations (EC) No 859/2009 and (EU) 2015/1428;
       
    [Commission Regulation (EC) No 245/2009 of 18 March 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for fluorescent lamps without integrated ballast, for high intensity discharge lamps, and for ballasts and luminaires able to operate such lamps](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523267929129&uri=CELEX:32009R0245)
    , OJ L76/17, 24.3.2009 and amendments Commission Regulations (EC) No 347/2010 and (EU) 2015/1428; 
    [Commission Regulation (EU) No 1194/2012 of 12 December 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for directional lamps, light emitting diode lamps and related equipment](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523268097398&uri=CELEX:32012R1194)
    , OJ L342/1, 14.12.2012 and amendment Commission Regulation (EU) 2015/1428 (ecodesign regulations)
:   [(3)](#footnoteref3)

     
       
    [Commission Delegated Regulation (EU) No 874/2012 of 12 July 2012 implementing Directive 2010/30/EUC of the European Parliament and of the Council with regard to energy labelling of electrical lamps and luminaires](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523268170086&uri=CELEX:32012R0874)
    , OJ L258/1, 26.09.2012 and amendment Commission Delegated Regulation (EU) No 518/2014 (energy labelling regulation)
:   [(4)](#footnoteref4)
     A control gear may include transforming the supply and starting voltage, limiting operational and preheating current, preventing cold starting, correcting the power factor and/or reducing radio interference.
:   [(5)](#footnoteref5)

    [Ecodesign impact accounting – Overview report for the European Commission DG Energy, VHK December 2016](https://ec.europa.eu/energy/sites/ener/files/documents/eia_ii_-_overview_report_2016_rev20170314.pdf)
:   [(6)](#footnoteref6)
     
       All the parts in italic in the text are common to the other impact assessments presented for the 2018 package.
:   [(7)](#footnoteref7)

     
       
    [Communication From The Commission To The European Parliament, The Council, The European Economic And Social Committee, The Committee Of The Regions And The European Investment Bank - A Framework Strategy for a Resilient Energy Union with a Forward-Looking Climate Change Policy. COM/2015/080 final.](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1520582754591&uri=CELEX:52015DC0080)
     [(]( ()
    <Energy Union Framework Strategy>
    <)>
:   [(8)](#footnoteref8)

     
       
    [Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions - Upgrading the Single Market: more opportunities for people and business COM/2015/550 final. 28 October 2015](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1520582577280&uri=CELEX:52015DC0550)
    . (Deeper and fairer internal market)
:   [(9)](#footnoteref9)

     
       
    [Ecodesign impact accounting – Overview report for the European Commission DG Energy, VHK December 2016](https://ec.europa.eu/energy/sites/ener/files/documents/eia_ii_-_overview_report_2016_rev20170314.pdf)
:   [(10)](#footnoteref10)

     
       Impact Assessment report for the revision of lighting products. VHK November 2017
:   [(11)](#footnoteref11)

     
       Over 50 countries have legislation in place (see CLASP database 
    <https://clasp.ngo/>
     and the UNEP activity 
    [www.united4efficiency.org](http://www.united4efficiency.org)
    ).
:   [(12)](#footnoteref12)

     
       
    [Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products](http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009L0125)
    . OJ L OJ L 285, 31.10.2009, p. 10 (Ecodesign Framework Directive)
:   [(13)](#footnoteref13)

     
       
    [Regulation (EU) 2017/1369 of the European Parliament and of the council of 4 July 2017 setting a framework for energy labelling and repealing Directive 2010/30/EU](about:blankhttp://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32017R1369)
    . OJ L 198, 28.7.2017, p. 1 (Energy Labelling Framework Regulation)
:   [(14)](#footnoteref14)

     
       
    <Study on the impact of the energy label – and potential changes to it – on consumer understanding and on purchase decisions>
     [- . LE London Economics and IPSOS, October 2014]( - . LE London Economics and IPSOS, October 2014)
:   [(15)](#footnoteref15)

     
       Commission Recommendation (EU) 2016/2125 of 30 November 2016 on guidelines for self-regulation measures concluded by industry under Directive 2009/125/EC of the European Parliament and of the Council; OJ L 329, 3.12.2016, p.109
:   [(16)](#footnoteref16)
     Verification tolerances are used by the national authorities when they test products to verify their compliance with the legislation, If the resulting value from the verification exceeds by X% the value declared by the manufacturer, the product is not compliant.
:   [(17)](#footnoteref17)

     
       
    [Communication from the Commission Ecodesign Working Plan. COM(2016) 773 final, Brussels, 30 November 2016.](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1520583455760&uri=CELEX:52016DC0773)
     (Ecodesign Working Plan 2016-2019)
:   [(18)](#footnoteref18)

     
       
    [Communication From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions Closing The Loop - An EU Action Plan For The Circular Economy](Communication From The Commission To The European Parliament, The Council, The European Economic And Social Committee And The Committee Of The Regions Closing The Loop - An EU Action Plan For The Circular Economy ) 
    (Circular Economy Initiative)
:   [(19)](#footnoteref19)

     
       
    [Directive 2010/30/EU of the European Parliament and of the Council of 19 May 2010 on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products.](http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0030)
     OJ L 153, 18.6.2010, p. 1.
:   [(20)](#footnoteref20)

     
       
    [Global agreement in response to climate change of 2015](http://unfccc.int/paris_agreement/items/9485.php)
     
    <(>
    <Paris Agreement>
    <)>
:   [(21)](#footnoteref21)

    [Protocol to abate acidification, eutrophication and ground-level ozone of 1999](http://www.unece.org/env/lrtap/multi_h1.html)
     (Gothenburg Protocol)
:   [(22)](#footnoteref22)

     
        See footnote 14
:   [(23)](#footnoteref23)

     
       
    <https://ec.europa.eu/clima/policies/ets_en>
     (ETS)
:   [(24)](#footnoteref24)

     
    [Communication of the commission to the European Parliament and the Council European Security Strategy](http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52014DC0330&qid=1407855611566)
    . COM/2014/0330 final.
:   [(25)](#footnoteref25)
     In 2015, an amendment to the current ecodesign regulations (Commission Regulation (EU) 2015/1428) postponed the phase-out of non-directional halogen lamps from 2016 to 2018, but this is not at all enough to justify such a difference in energy savings.
:   [(26)](#footnoteref26)

     
       Data from the Model for European Light Sources Analysis by VHK (MELISA; 2017 update). In the model, BAU2008 is the scenario "business-as-usual from the year 2008", meaning how the situation would have evolved up to 2030 if no measure had been taken from 2008.
:   [(27)](#footnoteref27)

     
       After electric motors.
:   [(28)](#footnoteref28)

     
       Eurostat Energy Balance Sheets, 2017 edition, 2015 data
:   [(29)](#footnoteref29)

     
       From 20 lumen per Watt to 70-90 lumen per Watt (lm/W).
:   [(30)](#footnoteref30)

     
       VHK light source database 2015-2017 (4000 models)
:   [(31)](#footnoteref31)

     
       
    [Directive 2010/30/EU of the European Parliament and of the Council of 19 May 2010 on the indication by labelling and standard product information of the consumption of energy and other resources by energy-related products.](http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32010L0030)
     OJ L 153, 18.6.2010, p. 1. (Energy Labelling Framework Directive)
:   [(32)](#footnoteref32)

     
       
    [Commission Staff Working Document Impact Assessment Accompanying the document Proposal for a Regulation of the European Parliament and of the Council setting a framework for energy efficiency labelling and repealing Directive 2010/30/EU](https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521474018907&uri=CELEX:52015SC0139)
    . SWD/2015/0139 final - 2015/0149. (Impact Assessment Energy Labelling Regulation)
:   [(33)](#footnoteref33)

     
       Lights can act as repeaters (e.g. WiFi) or access points for communication signals (e.g. in building automation); can detect presence, daylight or sound; can monitor air quality and visually ‘notify’ certain ‘events’ (mail, door ringing); and so on.
:   [(34)](#footnoteref34)
     'T8' means a tubular fluorescent light source with diameter of approximately 26 mm, as defined in harmonised standards. The tube can be straight (linear) or bent (e.g. U-shaped, circular).
:   [(35)](#footnoteref35)

     
       For more details: 
    [Ecodesign impact accounting – Overview report for the European Commission DG Energy, VHK December 2016](https://ec.europa.eu/energy/sites/ener/files/documents/eia_ii_-_overview_report_2016_rev20170314.pdf)
     and Annex 9
:   [(36)](#footnoteref36)

     
       Over 50 countries have legislation in place (see CLASP database 
    <https://clasp.ngo/>
     and the UNEP activity 
    [www.united4efficiency.org](http://www.united4efficiency.org)
    ).
:   [(37)](#footnoteref37)

     
       In the last years EU traditional lighting companies did not keep a competitive edge through energy-efficient innovation at the expected levels: previously announced innovations promising efficacy levels of 200-300 lm/W do not materialise in the market and new announcements are scarce.
:   [(38)](#footnoteref38)

     
       The COAG Energy Council agreed on 20/4/2018 to introduce minimum standards for LEDs in Australia and New Zealand by 2020/2021 (
    <http://www.coagenergycouncil.gov.au/sites/prod.energycouncil/files/publications/documents/16th%20COAG%20Energy%20Council%20Communique%20Final.pdf>
    ). In the US the standard body NEMA developed norms for LED quality which are not yet in the EU, e.g. for flicker and the stroboscopic effect.
:   [(39)](#footnoteref39)

     
       The regulations are built on classification of lamps for household and tertiary uses that no longer fully reflect today's reality. For example: LEDs are in scope of Regulation (EU) 1194/2012 which is intended for household-type lamps and not of Regulation (EC) 245/2009 on office and street lighting).
:   [(40)](#footnoteref40)

     
       Commission Regulation (EU) 2015/1428 was a first step to better regulate the exemptions for special purpose lamps which are often energy inefficient, but ambiguities remain (e.g. for decorative lamps or for the appealing message that they send, being sold as ‘shock-proof’, ‘low-electromagnetic interference’, ‘low UV emission’, etc.).
:   [(41)](#footnoteref41)

     
       Ecodesign and energy labelling together. VHK, Ecodesign Impact Accounting, study for the European Commission, March 2016.
:   [(42)](#footnoteref42)

     
       From Impact Assessment Study 2018, VHK. For completeness, another main cause is consumers' preference for halogen lamps rather than for compact fluorescent lamps as replacements for the phased out incandescent lamps. Fluorescent lamps are much more energy efficient than halogens but were not well perceived by many consumers due to e.g. unpleasant light and warm up time.
:   [(43)](#footnoteref43)

     
       See Annex 5.
:   [(44)](#footnoteref44)

     
       Lighting products are in scope of 
    [Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 On Waste Electrical and Electronic Equipment](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1520587696817&uri=CELEX:32012L0019)

    (WEEE Directive). 
    <The recycling requirements in Article 8(2) of the WEEE Directive are not directly applicable to product manufacturers, they are applicable to recyclers. Hence manufacturers are not always incentivised to design their products in view of this requirement.>
     [See Section 6.2.3.]( See Section 6.2.3.)
:   [(45)](#footnoteref45)

     
       The European lighting industry is mainly represented by LightingEurope.
:   [(46)](#footnoteref46)
     An Original Equipment Manufacturer (OEM) is a company that produces parts and equipment that may be marketed by another manufacturer.
:   [(47)](#footnoteref47)

     
       The company is now separate from former mother-company Philips and is quoted on the stock exchange. Its name will soon change to ‘Signify’, to reflect the separation from Philips.
:   [(48)](#footnoteref48)

     
       Non-American parts of GE have been bought by a Hungarian company in 2018. GE is also selling the rest of its lighting business.
:   [(49)](#footnoteref49)

     
       Revenues and employment figures relate to light sources. They do not include the production, sales and installation of luminaires, nor the design and installation of lighting systems in the non-residential sector. In the current regulation, the luminaire manufacturers are in scope of energy labelling only.
:   [(50)](#footnoteref50)

     
       Zumtobel Group, Annual Financial Report 2014/15
:   [(51)](#footnoteref51)

     
       Consumers are represented by the Bureau Européen des Unions de Consommateurs (BEUC) and the European Association for the Co-ordination of Consumer Representation in Standardisation (ANEC).
:   [(52)](#footnoteref52)

     
       Environmental organisations are represented by the European Environmental Citizens Organisation for Standardisation (ECOS), the European Environment Bureau (EEB), TopTen, the Collaborative Labelling and Appliance Standards Program (CLASP).
:   [(53)](#footnoteref53)

     
       
    [Consolidated version of the Treaty on the Functioning of the European Union.](http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:12012E/TXT)
     OJ C 326, 26.10.2012, p. 47 (TFEU)
:   [(54)](#footnoteref54)

    <https://ec.europa.eu/info/sites/info/files/file_import/better-regulation-toolbox-17_en_0.pdf>
     [(]( ()
    <Better Regulation Toolbox>
    <)>
:   [(55)](#footnoteref55)

     
       
    [Inception impact assessment - Regulatory measures on the review of ecodesign requirements for lighting products](https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-476175_en)
     and 
    [Inception impact assessment - Regulatory measures on the review of energy labelling for lighting products](https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-476111_en)
:   [(56)](#footnoteref56)
     See also Annex 2.
:   [(57)](#footnoteref57)
     
       Main point of contention amongst stakeholders (see Annex 5).
:   [(58)](#footnoteref58)
     
       For products placed on the market before the date of application of the new label and that will be on the shelves of dealers with the old label after 1 June 2022, suppliers would need to provide dealers with a sticker with the new label on the request of dealers until 1 June 2022.
:   [(59)](#footnoteref59)

     
       This will simplify life to dealers and suppliers and significantly reduce their costs for re-labelling. See an estimation of the costs in Section 6.4. Nine months is set following similar derogations in the new framework regulation for energy labelling for e.g. products in stock of dealers ceasing their activity.
:   [(60)](#footnoteref60)

     
       Method to evaluate the performance of the appliance, including determination of the need and value of the correction factors.
:   [(61)](#footnoteref61)
     For LEDs the efficiency does not strongly depend on the amount of light output.
:   [(62)](#footnoteref62)
     With the sole exception for LED technology, but without specifying which LED type.
:   [(63)](#footnoteref63)
     L=2.0 for network connected light sources.
:   [(64)](#footnoteref64)
     'T8',means a tubular fluorescent light source with diameter of approximately 26 mm, as defined in harmonised standards. The tube can be straight (linear) or bent (e.g. U-shaped, circular). Linear fluorescent (LFL) T8 2-foot’, ‘LFL T8 4-foot’ or ‘LFL T8 5-foot’ means a linear T8 fluorescent light source with a length of approximately 600 mm (2 feet), 1200 mm (4 feet) or 1500 mm (5 feet) respectively, as defined in harmonised standards.
:   [(65)](#footnoteref65)

     
       See details in Annex 10.
:   [(66)](#footnoteref66)
     
       This is a good compromise between the different interests: the Commission would keep its line of precise exemptions and the theatre sector would not suffer from a whole ban. .
:   [(67)](#footnoteref67)
     
       Removed parameters include starting time, warm-up time, switching cycles, UV-radiation, power factor (except displacement factor for LEDs), equivalence with incandescent lamps, premature failure rate, lifetime (except for LEDs), efficiency during dimming, lower output limit for dimming.
:   [(68)](#footnoteref68)

       OJ L 346, 20.12.2016, p. 51.
:   [(69)](#footnoteref69)

     
       A free-rider problem occurs when those who benefit from resources, goods, or services do not pay for them, which results in an under-provision of those goods or services. (Baumol, William (1952). Welfare Economics and the Theory of the State. Cambridge, MA: Harvard University Press.)
:   [(70)](#footnoteref70)

     
       ENER Lot 8/9/19 preparatory study, Task 6 report, 
    <http://ecodesign-lightsources.eu/documents>
:   [(71)](#footnoteref71)

     
       High-pressure mercury lamps have been effectively phased out by the minimum energy efficiency requirements in Commission Regulation (EC) No. 245/2009 starting from April 1st 2015.
:   [(72)](#footnoteref72)

     
       VHK light source database 2015-2017 (4000 models)
:   [(73)](#footnoteref73)

     
       See the Task 2 and Task 3 reports of the Lot 8/9/19 preparatory study on Light Sources.
:   [(74)](#footnoteref74)

     
       These changes mainly regard the lifetime (longer), average luminous flux, power and efficacy of LFL and HID-lamps. The lifetime for LEDs substituting LFL and HID was also increased. To enable lifetime to be variable with the years, a lifetime distribution was introduced for LFL T8t, LFL T5, HPS, MH and LEDs substituting these lamps. The main effect of these changes, with respect to results reported in Task 7 of the Light Sources study, was that energy savings in 2020 and 2025 slightly decreased while savings in 2030 increased.
:   [(75)](#footnoteref75)

    ‘Accelerating the Global Adoption of Energy-Efficient Lighting’, UN Environment – Global Environment Facility, United for Efficiency (U4E), U4E policy guide series, UNEP 2017, in particular figure 4 (based on US DoE 2016 data).
:   [(76)](#footnoteref76)
     PRIMES is the main modelling for energy that the European Commission, DG Energy, uses.
:   [(77)](#footnoteref77)

     
       For the conversion from electricity to primary energy, it reflects the primary energy efficiency of electricity generation and distribution.
:   [(78)](#footnoteref78)

     
       
    [Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency, amending Directives 2009/125/EC and 2010/30/EU and repealing Directives 2004/8/EC and 2006/32/EC](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1399375464230&uri=CELEX:32012L0027)
    . OJ L 315, 14.11.2012, p. 1
:   [(79)](#footnoteref79)
     
       
    [Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on Waste Electrical and Electronic Equipment](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1520587696817&uri=CELEX:32012L0019)

    (WEEE Directive).
:   [(80)](#footnoteref80)
     Meaning industry, wholesale and retail, installation and maintenance.
:   [(81)](#footnoteref81)

     
       Experience from the past learns that both manufacturers and users tend to anticipate Ecodesign measures. In addition, existing products in stock can still be sold after the phase-out date. The phase-out of a product is therefore never abrupt at the regulatory date, but more gradual. The analysis model reflects this, see details in Annex 4.6.
:   [(82)](#footnoteref82)
     Installation and Maintenance costs for the residential sector are assumed to be zero. In a non-residential context, light sources are typically installed by dedicated personnel. The unit time goes from 3 to 15 minutes, depending on the lamp type. Luminaires installation, their rewiring and change of control gear are not included. Due to the increasing lifetime of light sources, less replacements take place and thus installation revenues decrease with time. Maintenance costs are a share of annual luminaire cleaning costs assigned to light sources. The unit time depends on the ease of accessibility of the luminaires. As the quantity of light sources in use increases with time, maintenance revenues increase. Cleaning a LED luminaire is assumed to take the same time as cleaning a conventional luminaire. For both Installation and Maintenance, a labour cost of EUR 37/hour is assumed.
:   [(83)](#footnoteref83)

     
       The development of innovative energy-efficient technologies at competitive prices has been observed with the introduction the current ecodesign and energy labelling regulation (See also Annex 9). It is assumed that this will be the case for a revised measure as well.
:   [(84)](#footnoteref84)

     
       Data are for the ‘MEErP’ electricity prices (with 4% escalation). A sensitivity analysis was performed for PRIMES prices (Annex 4) which does not change conclusions.
:   [(85)](#footnoteref85)
     
       The estimation comes from LightingEurope with reference to the obligations to insert data on all products with an energy label in the database EPREL, following the new Framework Regulation for energy labelling.
:   [(86)](#footnoteref86)
     Calculations assume 2500 lighting suppliers in the EU, 2 million luminaire models (halfway between 1 million and 3 million) and that 40% of these luminaires will need an energy label for light sources for being fully-integrated luminaires. 1 hour work of an employee for every luminaire is assumed. The costs for registration in EPREL assume an employee tariff of EUR 27 per hour (the 2017 Eurostat average in the whole economy excluding agriculture and public administration). A cost of EUR 1000 for ICT support for every lighting manufacturing company is also assumed. Calculations are cautious: EUR 27 is the tariff for an unskilled employee, but as the validation in EPREL would be relevant to certify compliance of the lighting products with EU legislation, it is highly possible that the validation of the data in EPREL will be done by employees with a certain degree of responsibility.
:   [(87)](#footnoteref87)
     For instance, if an SME produces a yearly turnover of EUR 5 million with 10 employees, EUR 0.5 million per year would be saved (source: LightingEurope).
:   [(88)](#footnoteref88)
     
       Calculations assume that suppliers will need to provide a new label for 10% of the annual 1250 million lamps sold with a label, because 10% will stay on shelves longer than nine months (see Section 5.2.2). The cost to print a label is assumed at EUR 0.03. The costs for dealers assume an employee tariff of EUR 14.30 per hour representative for shop sale workers. Data are from the Impact Assessment of the new Framework Regulation for energy labelling.
:   [(89)](#footnoteref89)

     
       Source: 2015 Review study, Task 4 and Task 7 reports.
:   [(90)](#footnoteref90)
     
       The flicker and stroboscopic phenomena are undesired effects in visual perception. The term ‘flicker’ refers to unacceptable light variation that is directly perceived by an average observer. ‘Stroboscopic effect’ is an effect which may become visible for an average observer when a moving or rotating object is illuminated. Lighting products with flicker or stroboscopic effect are considered not good quality lighting.
:   [(91)](#footnoteref91)
     
       
    <http://eepliant.eu/images/Documents/WP1/EEPLIANT2014-Final-Report-12-12-2017.pdf>
:   [(92)](#footnoteref92)
     
       See Annex 5,
:   [(93)](#footnoteref93)
     
       74% of respondents agreed on the idea that lamps should be tested against the flicker effect and 60% find it a relevant piece of information when they buy lamps (11% and 8% were against, the others had no opinion). See Annex 2.
:   [(94)](#footnoteref94)
     In 2013 the European Commission issued a mandate to the standardisation bodies CEN/CENELEC to develop standards on flicker and stroboscopic effects. In April 2017 CEN/CENELEC completed the task by making reference to the work done by other international standardisation bodies: in IEC Technical Report TR 61547-1:2015 ‘Equipment for general lighting purposes - EMC immunity requirements - Part 1: An objective voltage fluctuation immunity test method’ and in CIE Technical Note TN 006:2016 ‘Visual Aspects of Time-Modulated Lighting Systems – Definitions and Measurement Models’. The criteria and the metrics 𝑃stLM for flicker and SVM for stroboscopic are reported in the Technical Note.
:   [(95)](#footnoteref95)

     
       IEA 4E Solid-State Lighting Annex, Potential Health Issues of Solid State Lighting, Final Report, 24 September 2014, 
    <http://ssl.iea-4e.org/task-1-quality-assurance/health-aspects-report>
     

     
       
    <http://ec.europa.eu/health/archive/ph_risk/committees/04_scenihr/docs/scenihr_o_019.pdf>

       
    <http://ec.europa.eu/health/scientific_committees/emerging/docs/scenihr_o_035.pdf>

     
       
    <http://ec.europa.eu/health/scientific_committees/environmental_risks/docs/scher_o_124.pdf>

     
       
    <http://ec.europa.eu/health/scientific_committees/environmental_risks/docs/scher_o_159.pdf>

    In 2016 the Commission requested the Scientific Committee on Health. Environmental and Emerging Risks (SCHEER) to provide a scientific opinion focusing on potential risks to human health of LEDs. The final Opinion was published on 12 July 2018 (https://ec.europa.eu/health/sites/health/files/scientific\_committees/scheer/docs/scheer\_o\_011.pdf). The SCHEER concluded that there is no evidence of direct adverse health effects from LEDs in normal use (lamps and displays) on the general healthy population. Although there are cellular and animal studies showing adverse effects raising concerns, particularly in susceptible populations, their conclusions derive from results either obtained using exposure conditions that are difficult to relate to human exposures or using exposure levels greater than those likely to be achieved with LED lighting systems in practice.
:   [(96)](#footnoteref96)
     See footnote 78.
:   [(97)](#footnoteref97)
       See details in Annex 6. The methodology is in line with other publications on the issue, e.g.: ‘Cambridge Econometrics, Assessing the Employment and Social Impact of Energy Efficiency, Cambridge Econometrics in collaboration with E3M-Lab, Warwick Institute for Employment Research and ICF International, main report and annex, November 2015’, and ‘Europe Economics, The Economic Impact of the Domestic Appliances Industry in Europe, Report for the European Committee of Domestic Equipment Manufacturers (CECED), London, April 2015’.
:   [(98)](#footnoteref98)

     
       MSAs (Spain, Poland, Slovenia, Estonia, Denmark, Italy, Czech Republic, Malta, Luxembourg, Slovakia, Bulgaria and Cyprus) also reported a lack of (financial and human) resources in a survey done in 2016. 
    <http://ec.europa.eu/DocsRoom/documents/15241/attachments/1/translations>
:   [(99)](#footnoteref99)
     Ecodesign requirements are energy efficiency, functional and information requirements.

[Top](#document1)

Annex 1: Procedural information

1.Lead Directorates General (DG), Decide Planning/CWP references

DG ENER is the lead DG for the Ecodesign and Energy labelling regulation for lighting products.

Decide planning number of the underlying initiative for the review of ecodesign requirements for lighting products is PLAN/2016/440 (inception impact assessment published on 23/01/2018 at 
<https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-476175_en>
).

Decide planning number of the underlying initiative for the review of energy labelling for lighting products is PLAN/2016/438 (inception impact assessment published on 23/01/2018 at 
<https://ec.europa.eu/info/law/better-regulation/initiatives/ares-2018-476111_en>
).

The following DGs (Directorates General) have been invited to contribute to this impact assessment: ENER (Energy), SG (Secretariat-General), GROW (Internal Market, Industry, Entrepreneurship and SMEs), ENV (Environment), CNECT (Communications Networks, Content and Technology), JUST (Justice and Consumers), ECFIN (Economic and Financial Affairs), REGIO (Regional policy), RTD (Research and Innovation), CLIMA (Climate Action), COMP (Competition), TAXUD (Taxation and Customs Union) EMPL (Employment), MOVE (Mobility and Transport), TRADE (Trade) and the JRC (Joint Research Centre) were consulted on the draft IA in April 2018.

2.Organisation and timing

The last Ecodesign Working Plan 2016-2019, adopted in November 2016, confirms that lighting products continue to be a priority product group. Furthermore, the recent Energy Label Regulation (EU) 2017/1369 stipulated that lighting products are one of the five priority subjects for which the Commission should adopt a new energy label regulation in accordance with the said overall regulation by 2 November 2018.

Article 19 of the Ecodesign Directive foresees a regulatory procedure with scrutiny for the adoption of implementing measures. Subject to qualified majority support in the Regulatory Committee and after scrutiny of the European Parliament and of the Council, the adoption of the measure by the Commission is planned for the end of 2018.

3.Consultation of the RSB

The present impact assessment report was submitted to the Regulatory Scrutiny Board (RSB) on 16/05/2018.

Following a meeting on 13 June 2018, on 18 June 2018 the RSB delivered a positive opinion with reservations. The draft impact assessment was subsequently improved, based on the RSB’s Opinion
[1](#footnote1)
 and the horizontal and specific technical comments that the RSB sent prior to the meeting of 13 June 2018. The table below shows how those recommendations are addressed in this revised impact assessment report.

|  |  |
| --- | --- |
| RSB Opinion 18.06.2018 | Where and how the comments have been taken into account |
| (B) Main considerations | |
| (1)The report does not sufficiently analyse current exemptions, i.e. explain what they cover, why they remain relevant, alternative ways to close loopholes, and the associated impacts. | Annex 11 is added to compare exemptions in the current legislation with the exemptions proposed with this review. |
| (2)The report does not integrate circular economy aspects comprehensively and in a way which is consistent across ecodesign products. It does not impact assess them either. | General explanations were added in Section 6.1 and specific explanations in Section 6.2.3. |
| (C) Further consideration and recommendations for improvement | |
| (1)The report relies mostly on stakeholder views and model simulations. It does not refer to e.g. horizontal or product specific evaluations that might have informed this initiative. It should present supporting evidence from such evaluations. It should also clarify what expectations were of the original legislation, how outcomes have been different from what was expected, and what lessons to draw from this. Key conclusions should directly feed into the problem definitions, and evaluation evidence should be summarised in the relevant annex. | Section 2.1 is added titled "How the problems are defined". |
| (2)The exemptions to the proposed rules should be transparently presented and their rationales explained in detail (e.g. exemptions for theatre lamps). This might involve adding a dedicated section on exemptions and loopholes. If some exemptions involve political as well as technical decisions, those choices should be duly reflected in policy suboptions. It should spell out the exemptions which will be kept and whether the preferred option includes new ones. | Annex 11 is added to compare exemptions in the current legislation with the exemptions proposed with this review. |
| (3)The circular economy dimension of the initiative needs clarification. In particular, the report should explain how and to what extent the measures on luminaires (i.e. integrated lighting units) would contribute to the circular economy objective. It should explain why other measures such as recyclability are not considered. | General explanations were added in Section 6.1 and specific explanations in Section 6.2.3, including on recyclability. |
| (4)The report should indicate the main limitations, risks and uncertainties of the methodological choices made for analysing the impacts of lighting products. This information should clarify how robust the model-based estimates are. | An explanation is added in Section 6.1. |
| (5)The report should better explain the value added of maintaining an energy label when the potential savings for consumers are negligible or even negative | Clarification is made in Sections 6.4, 6.2.1 and 5.3.4. Table 11 shows that the overall effect at 2030 for consumers when considering acquisition costs and electricity costs is positive for all options, including the one that supposes to review only the energy label regulation. |
| (6)For the preferred option, the report should include a REFIT reporting table on the quantified results from simplification and administrative burden reduction. The analysis should clarify the burden reduction of replacing the energy label for luminaires by similar information on the package. | The REFIT table in Section 8.2 and Table 18 in Annex 3 are adapted accordingly.  More explanation is also added in Section 6.5.  Moreover, more explanation is added in Section 5.2.2 on the reasons to replace the energy label for luminaires by similar information on the package. |
| (7)This report should be better aligned with the impact assessments that accompany the other proposals in this package of proposals for implementing legislation regarding ecodesign and energy labelling. | Alignment was checked, the structure is the same. |
| Other comments transmitted directly to the author DG prior to the RSB meeting | |
| (1)It is not clear whether and where in the text the criteria of Article 16(2) of the Energy Labelling Regulation are being fulfilled. | Explanation is added in Section 7.3. |
| (2)Explain better if the phase out of existing light sources is only based on efficiency requirements or also on other factors. Explain better the reasoning for the light sources that would be instead still allowed on the market. | Explanation is added in Section 5.2.3. |
| (3)Explain better the rationale for introducing a new formula for the energy label. | Explanation is added in Section 5.2.2. |
| (4)The report could wait for the publication of the Scientific Committee for Health – SCHEER report on effects on health for LEDs | The SCHEER report was published on 12 July 2018: the text was updated and a summary of the main conclusions of the report added.. It is to be noted that the SCHEER report is the last one of many reports on the effect of artificial lighting on health. Clarity on this point is added in Section 6.6.2. |
| (5)Important concepts should be explained when they are used for the first time (e.g. control gears, luminaire, verification tolerances, BAU2008) | Definitions are added or expanded in Section 1 and Section 2. |

4.Evidence, sources and quality

For this impact assessment, the main supporting studies were as follows:

·Omnibus review Study 2014
[2](#footnote2)
, which concluded that there was still significant energy savings potential for lighting products.

·Stage 6 review Study, done to verify the feasibility of last requirement in time of Commission Regulations (EC) 244 and 245.

·Review study 2015
[3](#footnote3)
, which concluded that about 50TWh electricity savings could be achieved by setting stricter ecodesign and energy labelling requirements (1/3 savings would come from the new labelling).

·Impact Assessment Study 2017 by an external consultancy company, Van Holsteijn and Kemna (VHK)
[4](#footnote4)
.

On the basis of this preparatory work, the Commission drafted the policy options presented in this IA.

Stakeholder input received during the above review studies, the two Consultation forum held on 7 December 2015 and on 7 December 2017 and the consultation on the Inception Impact Assessment for Ecodesign and Energy Label have also been taken into account.

A time-history and overview of the associated documents is provided in the table below, including preparatory and review studies, impact assessments, regulations, amendments.

Survey of Regulations and related documents on Lighting Products

|  |  |  |
| --- | --- | --- |
| Date | Document | Short Description |
| Non-directional Household Lighting (ENER Lot 19) Comm. Reg. (EC) 244/2009 | | |
| Oct. 2008 | Preparatory Study Lot 19 part 1 (VITO) | Ecodesign Preparatory Study on NDLS for domestic lighting |
| Mar. 2009 | Full Impact Assessment (EC) SEC(2009)327 | EC document accompanying regulation 244/2009 |
| Mar. 2009 | Commission Regulation (EC) No 244/2009 | Main lamp-types regulated: CFLi, HL, GLS |
| Sep. 2009 | Commission Regulation (EC) No 859/2009 | Amendment on 244/2009 for some UV-requirements |
| Jun. 2013 | Stage 6 Review Study (VHK) | Review of stage 6 of 244/2009 for MV-HL lamps |
| Tertiary Lighting (ENER Lots 8 and 9) Comm. Reg. (EC) 245/2009 | | |
| Jan. 2007 | Preparatory Study Lot 9 (VITO) | Ecodesign Preparatory Study on Public Street Lighting |
| Apr. 2007 | Preparatory Study Lot 8 (VITO) | Ecodesign Preparatory Study on Office Lighting |
| Mar. 2009 | Full Impact Assessment (EC) SEC(2009)324 | EC document accompanying regulation 245/2009 |
| Mar.2009 | Commission Regulation (EC) No 245/2009 | Main lamp-types regulated: LFL, CFLni, HID incl. related ballasts and luminaires |
| Apr. 2010 | Commission Regulation (EU) No 347/2010 | Amendments on regulation 245/2009 |
| Directional Lighting (ENER Lot 19) Comm. Reg. (EU) 1184/2012 | | |
| Nov. 2009 | Preparatory Study Lot 19 part 2 (VITO) | Ecodesign Preparatory Study on Directional lamps (DLS) |
| Mar. 2011 | Follow-up study (ECEEE, DEFRA) | Support study for preparation of regulation on DLS |
| Dec. 2012 | Impact Assessment (EC) SWD(2012)418 | EC document accompanying regulation 1194/2012 |
| Dec. 2012 | Commission Regulation (EU) No 1194/2012 | Main lamp-types regulated: Directional lamps, LEDs and related equipment |
| Sep. 2015 | Market Assessment directional lamps  [5](#footnote5) | Regarding the formal review of stage 3 of 1194/2012 for MV filament lamps |
| Nov. 2015 | Commission Communication COM(2015) 443  [6](#footnote6) | Confirms 2016 for Stage 3 of 1194/2012 for MV filament lamps |
| Labelling for Lighting | | |
| Sep. 1992 | Directive 92/75/EEC | Framework, legal basis for labelling of light sources (now repealed) |
| Jan. 1998 | Directive 98/11/EC | Labelling of household light sources (now repealed) |
| May 2010 | Directive 2010/30/EU | Framework, legal basis for labelling of light sources (repealing 92/75/EEC) |
| Jul. 2012 | Commission Delegated Regulation (EU) No 874/2012 | Labelling of electrical lamps and luminaires (repealing 98/11/EC) |
| Mar. 2014 | Commission delegated Regulation (EU) No 518/2014  [7](#footnote7) | Labelling on the internet |
| Jun. 2018 | Centerdata study | Study on the impact on consumer understanding and purchase decisions of energy labels for lighting products |
| General for several or all light sources | | |
| Feb. 2013 | CLASP study | Main points for the review of regulations 244/2009 and 245/2009 |
| Apr. 2014 | Omnibus Study (VHK) | Review of regulations 244/2009 and 245/2009 |
| Aug. 2015 | Commission Regulation (EU) 2015/1428  [8](#footnote8) | Amending 244/2009, 245/2009,1194/2012. Stage 6 of 244/2009 postponed to 2018; definitions of special purpose lamps revised |

  

Annex 2: Stakeholder consultation 

This Annex gives a brief summary of the consultation process. Details are given of how, who and which stakeholders were consulted. In addition, it explains how it was ensured that all stakeholders' opinion on the key elements relevant for the IA were gathered.

There has been extensive consultation of stakeholders during the review studies (see Annex 1.4), before and after and the consultation forum. External expertise on lighting products was collected and analysed during this process. The results of the stakeholder consultation during and after the Consultation Forum are further described in this section.

1.Review study and stakeholder consultations 

The Review Study 2015 started in January 2014 and was completed in October 2015. It followed the structure Methodology for Ecodesign of Energy related Products (MEErP)
[9](#footnote9)
.

The review study covered lighting products in the current scope of those regulations. A technical, environmental and economic analysis was performed. This assessed the need of updating the requirements for these products and to assess policy options. This was done as per the review clause of the regulation, and within the Ecodesign framework Directive and Energy Labelling Framework Directive since August 2017 replaced by the Energy Labelling Framework Regulation.

The review study was developed in an open process, taking into account input from relevant stakeholders including manufacturers and their associations, environmental NGOs, consumer organisations and MS representatives. To facilitate communication with stakeholders, dedicated website was set up on which the interim results and other relevant materials were published. The study website 
<http://ecodesign-lightsources.eu/documents>
 is still open for download of the study documents and stakeholder comments (status April 2018). During the study, two open consultation meetings were organised at the Commission premises in Brussels on 5 February 2015 and 14 June 2015. During these meetings, the preliminary study was discussed and validated.

The first meeting on 5 February 2015 was to discuss Tasks 0, 1, 2 and 3 of the study. Tasks 0 and 1 concerned the scope of the study, definitions, and existing EU and non-EU standards and legislation. Task 2 concerned market data (light source sales, lifetimes, stock, unit prices). Task 3 addressed the use of light sources, including average annual operating hours, luminous fluxes, powers and efficacies of light sources. Health aspects, end-of-life aspects and compatibility between dimmers and light sources were also discussed with stakeholders in Task 3.

Following the first meeting, stakeholders had time until 28 February 2015 to provide written comments. The minutes of the meeting can be found in Annex A of the Task 7 report of the study and on the website.

The second meeting held on 17 June 2015 was to discuss Tasks 4, 5 and 6. Task 4 extensively described technology aspects, concentrating on the expected efficacy increase and price decrease for LED lamps and on the expected speed of replacement of classic technology lamps by LED lamps and luminaires. Bills-of-Materials, including packaging, were also discussed as part of Task 4. Task 5 addressed the input and the results of the EcoReports, focusing on life cycle costs and environmental impacts of the various lamp types. Task 6 regarded design options and focused on the cost comparison of classic technology lamps and their LED replacement, and on payback times for investments in LED technology.

Stakeholders had time until 15 July 2015 to provide written comments, and until 30 August 2015 to provide inputs for the scenario analyses of Task 7. The minutes of the meeting and the stakeholders’ comments and inputs have been published on the project website and can be found in Annex B of the Task 7 report of the preparatory study.

The study team also engaged in several bilateral meetings with stakeholders.

2.Working Document and Consultation Forum

The Commission services prepared two Working Documents with ecodesign and energy labelling requirements based on the results of the Review Study 2015. The Working Documents were circulated to the members of the Ecodesign Consultation Forum for the meeting on 7 December 2015. The second and last version was circulated for and discussed at the Ecodesign Consultation Forum meeting of 7 December 2017. The Ecodesign Consultation Forum represents all EU Member States and EEA countries, together with industry associations and NGOs in line with Article 18 of the Ecodesign Directive.

The Working Documents and the stakeholder comments received in writing before and after the Consultation Forum meetings were posted on the Commission’s CIRCA system. Minutes of the Consultation Forum meeting of 7 December 2017 can be found in Annex 5. For this Forum, around 30 written comments were received from different MSs' representatives (11), industry associations, consumers’ associations and NGOs.

3.Results of stakeholder consultation during and after the Consultation Forum 

The comments of the main stakeholders on key features of the Commission services’ Working Document received during and after the Consultation Forum of 7 December 2017 can be summarized as follows:

·Scope and exemptions – Stakeholders agreed that the current definition of the scope and of the exemptions create loopholes. Exemptions should be better defined, and loopholes should be closed.

·Administrative burden – Stakeholders welcomed the attempt to simplify the legislation, especially the merging of the three ecodesign regulations. Most MSs also agreed on simplifying the tests for verification, especially for the lifetime test which today happens to be longer than the average permanence of a light source on the market, but there was no obvious solution.

·Energy efficiency requirements – Stakeholders agreed on the principle of phasing out fluorescent lamps (especially linear T8 lamps) but there was no agreement on the date. NGOs and some MS agreed on an ambitious date, while the agreement of other MSs, of industry and sectorial representatives would depend on the timing and on exemptions that will be accorded to certain sectors.

·Circular Economy – Stakeholders generally welcomed the principle to have more requirements on the circular economy aspects of lighting products, in particular about fully integrated luminaires and other non-dismountable products containing the light component. However, the lighting industry, the furniture industry and some MSs required for a proper assessment of the impact of these requirements, clear definition of responsibilities for manufactures of the containing products and timing.

·Verification tolerances - Environmental NGOs and most MSs welcomed the proposal for stricter verification tolerances.

·Energy label classes – Stakeholders generally welcomed the proposed classes and no-one strongly opposed them: class A and probably B will stay unpopulated, as requested in the new framework legislation.

·Re-labelling products – most stakeholders opposed the solution to re-label lighting products with a sticker, especially light sources were the label is printed on the package.

As a result, the following measures represent the consensus achieved (from Section 5.1):

1.the proposed new calculation formula and bands for energy labelling, which are the same in all options where an energy label is continued;

2.the proposed simplified tests that manufacturers apply to commercialise products and market surveillance apply to check compliance of the products, which are the same in the options that include the revision of the ecodesign legislation;

3.the discontinuation of the energy label specifically dedicated to luminaires, but with relevant information from the label kept on the packaging and improved;

4.fully-integrated luminaires will fall within both ecodesign and energy labelling generic requirements;

5.(i) a slightly reduced but more certain scope, where ambiguities about the products in scope are highly reduced; (ii) a change in the approach of how exemptions are defined, moving away from a definition based on the intended use of a product to clear exemptions based on technical characteristics and/or legislative reference;

6.The exemptions. The list of proposed exemptions and their comparison with what is exempted in the current legislation is provided in Annex 11;

7.the proposed list of light sources to be phased out is also the result of a long dialogue with stakeholders, with one crucial exception: the phase out of the linear fluorescent lamps T8.

Other measures are not proposed for discussion in the options in Section 5.2, despite there was no full agreement from all stakeholders. This is the case especially for the introduction of requirements that would protect consumers from products with bad quality or potential negative effects on health, like the flickering effect.

4.Open public consultation

An online public consultation (OPC)
[10](#footnote10)
 took place from 12th February to 7th May 2018, with the aim to collect stakeholders' views on issues such as the expected effect of potential legislative measures on business and on energy consumption trends.

The OPC contained a common part on Ecodesign and Energy labelling, followed by product specific questions on (i) refrigerators, (ii) dishwashers, (iii) washing machines, (iii) televisions, (iv) electronic displays and (v) lighting.

1230 responses were received of which 67% were consumers and 19% businesses (of which three quarters were SMEs and one-quarter large companies). NGOs made up 6% of respondents, and 7% were "other" categories. National or local governments were under 1% of respondents, and 0.25% came from national Market Surveillance Authorities.

The countries of residence of the participants were predominantly the UK (41%) and Germany (26%), with a second group of Austria, Belgium, France, the Netherlands and Spain comprising together some 17%. Nine other Member States comprised another 9.5% of replies, but residents in 12 EU Member States gave either zero or a negligible number of responses. Non-EU respondents comprised around 5% of replies.

It should be noted that of the 1230 respondents, 719 (58%) replied only to lighting related questions as part of a coordinated campaign related to lighting in theatres. This was considered to significantly distort the replies, and for some questions the “lighting respondents” were removed from the calculation. Furthermore, as respondents did not have to reply to all questions, a high rate of “no answer” was observed (from 5% - up to 90%), in addition to those who replied “don’t know” or “no opinion”. To reflect better the actual answers, the number of “no answers” was deducted and the remaining answers treated as 100%.

4.1.Overall results

The first part of the questionnaire asked general questions aimed at EU citizens and stakeholders with no particular specialised knowledge of ecodesign and energy labelling regulations.

When asked regarding whether their professional activities related to products subject to Ecodesign or Energy Labelling, two-thirds (67%) of business respondents replied in the positive, and one-third (33%) in the negative, with no "no answer" replies. Almost the same percentages for "yes" (63%) and "no" (37%) were given when the business entities were asked whether they or their members knew of the Ecodesign requirements for one or more of the product groups concerned by the questionnaire, although this was reduced to 50% "yes" and 50% "no" when asked about Energy Labelling.

In reply to the question: "In your opinion, does the EU energy label help you (or your members) when deciding which product to buy?" 56% of the total respondents to the OPC gave a positive answer. Of the remainder, around 22% cited "don't know or no opinion", 3% did not reply and 19% responded negatively.

However, looking only at the ‘lighting respondents’ (526 of the total 1230), 73% of them replied ‘No’, ‘Don't know or no opinion’, or ‘no answer’. Given that the ‘lighting respondents’ mainly focused their comments on a narrow issue related to the current exemption for theatre lighting under ecodesign, the replies of these respondents to the earlier questions cannot necessarily be considered representative. Therefore, the calculation was also done with “lighting respondents” removed. Then, 84% of the respondents to the OPC agree that the EU Energy Label helps when deciding which product to buy. Of the remainder, around 7% cited "don't know or no opinion" or did not reply and 9% responded negatively.

When asked where they would look to find additional technical information about a product, respondents listed the following (more than one response permitted), ranked by the options provided: manufacturer's website (82%), the booklet of instructions (50%), [the Ecodesign] product information sheet (47%), internet user fora (39%), the retailer's website (18%), and consumer organisations (10%).

Some 63% of the participants were in favour of including Ecodesign requirements on reparability and durability, and 65% of respondents considered that this information should be on Energy Labels.

Regarding the reparability of products, participants valued mostly as "very important" to "important" (in the range 62%-68%)
[11](#footnote11)
 each of the following: a warranty, the availability of spare parts, and a complete manual for repair and maintenance. The delivery time of spare parts was rated as 56% "very important" to "important".

Small and Medium Enterprises (SME) Consultation [SMEs < 250 employees]

One of the aims of the OPC was to gather specific information on SMEs' roles and importance on the market, and to acquire more knowledge on how the aspects related to the environmental impacts of these six product groups were considered by SMEs.

The quali-quantitative evaluation of the effect on SMEs of potential regulatory measures for the environmental impact of all six product categories gave the following results. Approximately 10.5% or replies were from SMEs. These SMEs were involved in the following activities (most popular cited first): (i) product installation, (ii) rent/ leasing of appliances, (iii) repair, (iv) retail of appliances or spare parts, (v) final product manufacture/ assembly, (vi) sale of second-hand appliances, (vii) "other" activities, and (viii) manufacture of specific components.

In the OPC responses, SMEs reported that they were aware of the Ecodesign and EU Energy Label requirements applicable to the products they were involved in. Nevertheless, SMEs mostly declined to respond (90%) or replied in "don’t know/ no opinion" (6%) when asked about the potential impact on their businesses per se, or potential impacts on SMEs compared to larger enterprises, of the introduction of resource efficiency requirements in the revised Ecodesign and Energy Labelling regulations. Of those SMEs who gave an opinion, some 3-4% considered that the impacts could be negative, and around 1% thought that the effects would be positive.

Responses relating specifically to lighting

Basically all respondents (1229 out of 1230) answered the questions on lighting products: the same numbers than for the overall results apply in terms of type and country of residence of respondents. 719 participants (58%) replied only on lighting.

With regards to whether ecodesign measures should be updated to take into account technological development, notably for LEDs, 75% answered yes; 11% answered no.

74% of respondents agreed on the idea that lamps should be tested against the flicker effect (11% disagreed) and 60% find it a relevant piece of information when they buy lamps (8% was against). The others had no opinion.

68% of respondents declared to dislike sealed fully integrated luminaires from where the light source cannot be removed, while 28% had no opinion on this issue.

With regards to what information respondents would like to have when they buy a light source, all options got consensus. Three of them got around 70% of positive answers (Quantity of light provided by the lamp; Lifetime; Warm/cold effect of LEDs). The Watt equivalence with old bulbs got the lowest result (54%) and the highest number of explicit "no" (14%). In details:

·Quantity of light provided by the lamp (expressed in Lumen): 74% yes, 2% no, no opinion 24%;

·Lifetime: 72% yes, 3% no, no opinion 26%;

·Warm/cold effect of LEDs: 69% yes, 4% no, no opinion 27%;

·Energy efficiency expressed in terms of lumen per Watt: 66% yes, 8% no, no opinion 27%;

·Watt equivalence with old bulbs (incandescents): 54% yes, 14% no, no opinion 32%.

Only 18% of the respondents indicated other information that they would like to have when they buy a light source. There are two main answers: the first is about the colour rendering of lamps. The second answer is about theatre lighting: in this case, more than answering to the question, the respondents raised their concern about the possible phase out from the market of light sources intended to be used in theatre and other stage contexts (this field was the only one where respondents could type messages).

Finally, with regard to the option to discontinue the energy label for luminaires, 30% of the respondents would like to keep the label as it is, while 28% would favour its replacement by a label that concerns only the light source which is contained in the luminaire. A high number – 37% – had no opinion. Only 5% favoured to discontinue the label for luminaires without an alternative.

5.IA

An IA is required when the expected economic, environmental or social impacts of EU action are likely to be significant. The IA for the review of the four regulations for lighting products (Commission Regulations (EC) No. 244/2009, (EC) No. 245/2009 and (EU) No. 1184/2012 for ecodesign; Commission Regulation (EU) No. 874/2012 was carried out between May 2017 and April 2018.

The data collected in the review studies, see Annex 1.4, served as a basis for the IA. Additional data and information was collected and discussed by the IA study team with industry and experts, and other stakeholders including MSs. During this process, several meetings were organised with industry and MSs experts. The additional data and information collection focused on:

·Additional market data on energy efficiency for the period 2015-2017;

·Update on lighting catalogues for the availability of LED replacements;

·Fine-tuning of the requirements;

·Fine-tuning of definitions;

·Investigation of various options for the phase out of T8 lamps;

·Sensitivity analysis regarding electricity tariffs;

·Extended information on SMEs, possible impacts;

·Extended information on specific sectors using T8 lamps.

In addition, inception impact assessments for the regulatory measures on the review of ecodesign and energy labelling requirements for this product group were published on 26 January 2018 for feedback until 23 February 2018. In total 17 comments were received for the ecodesign measure and 16 for the energy labelling measure.

In general, all stakeholders are in favour of Ecodesign and Energy labelling requirements for lighting products. The submitted feedback commented amongst others on the strictness of Ecodesign requirements, the quality of light, the blue light content and requirements that would make light sources easily replaceable//repairable in containing products.

Annex 3: Who is affected and how?

This annex explains the practical implications of a potential ecodesign and energy labelling measures based on implementation of the preferred policy option, see Section 5.2.2.

1.Practical implications of the initiative

The ecodesign regulation will apply to the manufacturers, importers and authorised representatives of lighting products in the scope of the regulations.

The energy labelling regulations will apply to the suppliers and the dealers of lighting products in the scope of the regulations.

They will need to comply with the ecodesign requirements summarised in 
[Table 17](#_Ref509409794)
.

Table 17: Summary of the Ecodesign requirements

|  |  |  |
| --- | --- | --- |
| Who | What | When |
| Manufacturers, importers and authorised representatives | New ecodesign requirements | 1 September 2021 |
| Manufacturers, importers and authorised representatives of products containing a light | Information requirements on the contained light | 1 September 2021 |
| Suppliers | Provide Energy labels rescaled from A to G | 1 May 2021 [12](#footnote12) |
| Dealers | Display Energy labels rescaled from A to G | 1 September 2021 |
|  | Remove products from the shelves if they do not have the new label | 1 June 2022 |

In addition to the above and to what described in the main text of this impact assessment, the following categories will be affected:

·Manufacturers of lighting-related electronics

With the ongoing rapid shift to LED lighting, manufacturers of lighting-related electronics are required to adjust from electronic control gears for classical lighting technologies to drivers for LEDs. Less efficient electro-magnetic control gears are phased out from the market since 2017 and have been replaced by more efficient, high-frequency electronic ones. These manufactures have a dynamic business also for the increasing trend to have ‘smart lights" with new features.

·Lighting designers

Lighting designers tend to be conservative as regards legislation on light sources, as they are afraid that the requirements may limit their design options. LED light sources pose both challenges and opportunities on design. LEDs are different from conventional light sources in many aspects, e.g. they are smaller, mainly directional and have different thermal characteristics. In parallel, lighting designers can exploit the higher controllability of LEDs, including new intensity-change and colour-change possibilities, also related to creating a human-centric lighting and the possibility for different methods of power supply (e.g. Power-over-Ethernet). On top, organic LEDs (OLED) offer large, flexible surfaces emitting a diffuse light and enable a new approach to luminaire design with a variety of new possibilities.

Lighting designers are represented by the International Association of Lighting Designers (IALD).

·Professional applications
   

In professional applications as offices, shops, hotels, restaurants, theatres, sports facilities, industry, street lighting, etc., the average burning hours for lights are longer than in households, typically between 2000 and 4000 hours per year. It is therefore expected that future LED lamps for professional use will differ from those for household use, being more expensive, but with higher efficiency and longer lifetime.

In many professional applications the importance of light quality and controllability will increase, to create a "human centric lighting". Lamps are inserted in control systems to regulate light in function of daylight availability or space occupancy.

For some professional applications the availability of LED retrofit lamps for existing luminaires is disputed. Even where LED retrofit lamps are available, it may be necessary to substitute the control gear and/or to perform a rewiring in the luminaire. Specific exemptions are investigated in the most problematic sectors (e.g. theatre/stage lighting; railways). Businesses and municipalities that have recently invested in non-LED lighting solutions following the ban of some mercury lamps in the current ecodesign legislation, have asked to take this into account to avoid another change at short term.

·Consumers

Due to more efficient and less expensive LED lighting products, this can decrease to EUR 80 in 2020 and to EUR 50 in the period 2025-2030
[13](#footnote13)
. An average household lamp burns around 500 hours per year. A LED lamp with a relatively low lifetime of 10 000 hours would on average last 20 years. Therefore light quality is a crucial aspect and consumers should be well informed on the lamp they buy.

2.Summary of costs and benefits

For the preferred option, 
[Table 18](#_Ref509410225)
 and 
[Table 19](#_Ref509411486)
 present the costs and benefits which will have been identified and assessed during the impact assessment process.

 

Table 18: Overview of Benefits (total for all provisions) as compared to the baseline– Preferred Option

|  |  |  |
| --- | --- | --- |
| I. Overview of Benefits (total for all provisions) – Preferred Option ECOEL2021 | | |
| Description | Amount | Comments |
| Direct benefits | | |
| Final Energy (Electricity) savings | 41.9 TWh/a by 2030  Cumulative 267 TWh up to 2030 | See Section 6.2.1  See Section 7.1 |
| GHG-emission reduction | 14.3 Mt CO2eq/a by 2030  Cumulative 94 Mt CO2eq up to 2030 | See Section 6.2.2  See Section 7.1 |
| Decreased consumer expenditure | EUR 7.7 billion less in 2030  Cumulative EUR 21 billion less up to 2030 | See Section 6.4  See Section 7.1 |
| Additional business revenue | EUR 1.1 billion extra in 2030  Cumulative EUR 29 billion extra up to 2030 | See Section 6.3.1  See Section 7.1 |
| Increased Employment | 59 000 jobs extra in 2025  23 000 jobs extra in 2030 | See Section 6.6.3 |
| Single regulation for all light sources | General simplification | Existing three Ecodesign regulations replaced by a single new regulation. Welcomed by all stakeholders |
| Market surveillance facilitated | Possibility to perform more compliance checks with the same resources | Due to unifying regulations into one; less parameters to verify; improved definitions for parameters and exemptions; shorter lifetime-related tests. The freed resources for other surveillance activities cannot be easily monetised. |
| Luminaire labels abolished | EUR 0.001 billion (as a result of EUR 34 million cost for suppliers and dealers for re-labelling and EUR 35 million savings from the abolished obligation to upload data in the database EPREL) | For dealers and for SMEs. The result has to be treated cautiously: the decrease in total administrative costs also means freed resources for other activities and higher turnover. See Sections 6.5 and 7.2. |
| Reduced risk of circumvention | More light sources complying with regulation | Improved definitions for exemptions; redefinition of verification tolerances |
| Support of innovation, R&D and improved competition | New features in LEDs for smart lights and human centric lighting | See Section 6.3.2 |

|  |  |  |
| --- | --- | --- |
| Indirect benefits | | |
| Circular economy | Incentive to have dismountable LED luminaires |  |

Estimates are relative to the baseline for the preferred option as a whole (i.e. the impact of individual actions/obligations of the preferred option are aggregated together.

Table 19: Overview of the additional costs as compared to the baseline – Preferred option

|  |  |  |
| --- | --- | --- |
| II. Overview of costs – Preferred option ECOEL2021 | | |
| What | Amount | Who |
| Acquisition costs | EUR 1.1 billion extra in 2030 (but total expenditure including energy consumption decreases – see Table 18) | Consumers |
| Installers revenue | EUR -0.2 billion in 2030 (but total business revenues increase – see Table 18) | Installers |

|  |  |  |
| --- | --- | --- |
| Table 20: Overview of stakeholder problems/challenges and main related actions in regulation | | |
| EU Stakeholder | Main problems / challenges | Main related actions in Regulation |
| Manufacturers of light sources | Declining sales of classical light sources.  Strong increase in LED sales, but more fragmented market and competition from low-cost low-quality from extra EU.  Investments required in R&D for LED, OLED and new features. | Set ambitious requirements on efficiency and quality of LEDs to be sold on EU28 market, to avoid price-war, to avoid dumping of low-cost and low-quality products from extra-EU, promoting and safeguarding investments of EU-manufacturers. |
| Manufacturers of luminaires (many SME’s) | LED- and OLED-luminaires require new design approach, but offer new possibilities.  Choice to be made between existing luminaires using LED retrofit lamps, integrated LED luminaires, and luminaires with replaceable LED modules.  Integration of new features; luminaires part of intelligently controlled lighting systems; trend towards human centric lighting.  Luminaire labelling is a burden and not effective. | Limit ecodesign requirements to light sources. Most luminaire suppliers buy the contained light sources, which will usually already be supplied with a document of conformity, so minimal burden for SMEs.  Take into account the demands that new features and integration in lighting systems pose on light sources and luminaires.  Abolish labelling for luminaires. |
| Manufacturers of lighting-related electronics | Decrease in sales of control gears for classical light sources. Increase in drivers for LEDs, but more competition from extra-EU.  Demand for new features and intelligent controls; new power supply methods (PoE).  New dimmer standard (2018).  Controls/dimmers built in lamps already by light source manufacturers. | Set ambitious requirements on efficiency and quality of control gears to be sold on EU28 market, to avoid price-war, to avoid dumping of low-cost and low-quality products from extra-EU.  Set standby requirements sufficiently strict to avoid excessive energy consumption, but sufficiently wide to enable new features and intelligent controls. |
| Lighting designers | Exploit new possibilities of LED and OLED.  Balance energy efficiency with lighting quality and new features.  Recalculate lighting systems for new light distribution from LEDs.  Implement intelligently controlled lighting systems and human centric lighting. | Combination of actions mentioned above for manufacturers.  Ensure OLEDs can be placed on the market. |
| Retailers and wholesalers | Dynamic market with shift from classical to LED products. LED models frequently changing. Introduction of new features.  Short term: stable or increasing revenue from LEDs; later: decrease in sales.  Increase of sales over internet.  Display energy labels; informing consumers. | Revision of energy label for light sources; general revision of information requirements.  Abolish labelling for luminaires. |
| Installation and maintenance (tertiary / industry) | Increased installation due to shift to LED: substitution of control gears, rewiring of luminaires, replacement of luminaires. Peak in 2020-2024, afterwards decrease.  Increased installation for lighting systems, (sensors, timers, switches, communication, controls, cables for PoE, etc.).  Maintenance: less substitutions of light sources and control gears (longer LED lifetime). More work to maintain lighting systems.  Increased complexity of work and shift to electronics. | Phase-out of inefficient lamps.  Stimulate quality / reliability of LEDs.  Do not penalize LED luminaires with replaceable light sources. |
| Market surveillance | Definitions, scope and exemptions not always clear or not objectively verifiable.  Too many parameters to test; tests too long and too costly. | General effort to unify and simplify existing regulations.  Improve definitions, scope, exemptions and try to remove remaining loopholes.  Simplify testing.  Revision of tolerances for verification. |
| Households | Now: Should I already buy LED?  Future: Which LED should I buy?  How many lumens should my new lamp have?  Is quality good? No induced health / discomfort problems?  Demand for new features (e.g. intensity/colour control from smartphone) | Improve energy label and information requirements.  Stimulate use of high efficiency, high quality LEDs, that do not have health problems.  Enable new features to be implemented, but without excessive energy consumptions (standby). |
| Professional users | Need for high efficiency and high lifetime, even if at slightly higher acquisition cost.  Importance of quality and controllability of light: trend towards human centric lighting.  Increased implementation of intelligently controlled lighting systems.  LEDs do not have lowest life cycle costs for all applications yet (2015). Expected by 2020.  Substitution of control gears or rewiring may be necessary to install LED retrofits: higher upfront costs.  For some existing luminaires LED retrofits are scarce; possible need to substitute entire luminaire: higher upfront costs.  Recent investments made in efficient office and street lighting. Time needed to recuperate this before passing to LED.  Increased use of ESCO’s and EPC. | Combination of other actions mentioned above.  Take into account new methods of power supply (e.g. PoE).  Set standby requirements sufficiently strict to avoid excessive energy consumption, but sufficiently wide to enable new features and intelligent controls.  Provide sufficient time for replacement of CFni, LFL, HID by LED, so that users can recuperate previous investments and prepare for luminaire substitutions. |
| Society | Meet EU policy objectives regarding energy efficiency, security of energy supply, reduction of CO2 emission, promoting the single market, stimulating EU business, and furthering innovation.  Ensure safety, protect health, increase well-being of EU citizens. | Set requirements on lighting products sold on EU28 market that do no lag behind those in major extra-EU economies.  Set requirements that ensure energy savings and reduction of environmental impact, while maintaining or increasing functionality and affordability, and avoiding negative impacts for the majority of the stakeholders.  Ensure quality of products on the market, to ensure safety, health, comfort. |

  

Annex 4: Analytical methods

ACRONYMS

1 Introduction to MELISA

2 Basic functional parameters

2.1 Basic functional parameters for non-LED base cases

2.2 Basic functional parameters for LED base cases

2.3 LED efficacy and price projections

3 General input parameters

3.1 Price shares per business sector

3.2 Electricity rates

3.3 Global Warming Potential

4 BAU-scenario

4.1 BAU-scenario assumptions

4.2 BAU-scenario, Sales

4.3 BAU-scenario, Stock

4.4 BAU-scenario, Electricity

4.5 BAU-scenario, GHG-emissions

4.6 BAU-scenario, User Expense for light sources

4.7 BAU-scenario, Revenues per business sector

5 ELOnly scenario

5.1 ELONLY scenario, assumptions

5.2 ELONLY scenario, Electricity

5.3 ELONLY scenario, GHG-emissions

5.4 ELONLY scenario, User Expense for light sources

6 ECOEL2021 scenario

6.1 ECOEL2021 scenario, model assumptions

6.2 ECOEL2021 scenario, Sales

6.3 ECOEL2021 scenario, Stock

6.4 ECOEL2021 scenario, Electricity

6.5 ECOEL2021 scenario, GHG-emissions

6.6 ECOEL2021 scenario, User Expense for light sources

7 ECOEL2tiers scenario

8 Scenario comparison, Summary and Conclusions

9 Sensitivity analysis for electricity rates

ACRONYMS

AR111
   Lamp shape: Wide and flat reflector lamp, 111 mm diameter

CFL
   Compact Fluorescent Lamp (all types)

CFLi
   CFL with integrated control gear

CFLni
   CFL without integrated control gear

CMH
   MH-lamp with ceramic technology

DLS
   Directional Light Source (light concentrated in a beam, spot light)

E
   Cap-type, screw-in

E14
   Cap-type, screw with 14 mm diameter

E27
   Cap-type, screw with 27 mm diameter

FL
   Fluorescent lamp (all types)

G
   Cap-type, push-in or push-in and turn

G4
   Cap-type with two pins at 4 mm distance for low-voltage

G53
   Cap-type with two pins at 53 mm distance for low-voltage

G9
   Cap-type with two pins at 9 mm distance for mains-voltage

GLS
   Incandescent, non-halogen, filament lamp (classic light bulb)

GLS R
   GLS reflector lamp, DLS

GLS X
   GLS non-reflector lamp, NDLS

GU4
   Cap-type with two pins at 4 mm distance for low-voltage

GU5.3
   Cap-type with two pins at 5.3 mm distance for low-voltage

GU10
   Cap-type with two pins at 10 mm distance for mains-voltage

GY6.35
   Cap-type with two pins at 6.35 mm distance for low-voltage

HID
   High-Intensity Discharge lamp (all types)

HL
   Halogen lamp (all types)

HL LV C
   Halogen Low-Voltage Capsule, with G4 or GY6.35 cap, NDLS

HL LV R
   Halogen lamp, Low-Voltage, Reflector type (mirrored), DLS:

   e.g. MR11-GU4, MR16-GU5.3, AR111-G53

HL MV C
   Halogen Mains-Voltage Capsule, with G9 cap, NDLS

HL MV E
   Halogen lamp, Mains-Voltage, most with E-cap, NDLS

HL MV L
   Halogen lamp, linear, double-ended R7s cap, NDLS

HL MV X
   Halogen lamp, Mains-Voltage, Reflector type (mirrored), DLS:

   e.g. MR16-GU10, R- and PAR-lamps with E14 and E27 caps

HPM
   High-Pressure Mercury lamp (type of HID)

HPS
   High-Pressure Sodium lamp (type of HID)

LED
   Light-Emitting Diode light source

LFL
   Linear Fluorescent Lamp (all types)

LFL T5
   LFL with diameter of 16 mm (5/8 inch), 14-80W, incl. circular

LFL T8
   LFL with diameter of 26 mm (8/8 inch) (all types)

LFL T8t
   LFL T8 with tri-phosphor technology

LFL T8h
   LFL T8 with halo-phosphor technology

LFL T12
   LFL with diameter of 38 mm (12/8 inch)

LFL X
   LFL other than T12, T8 and T5 (incl. e.g. T9, special FL, U-shaped, T5 ≤ 13 W)

LV
   Low-Voltage (less than 230 V, typically 12 or 24 V)

MH
   Metal-Halide lamp (type of HID)(all types)

MR11, MR16
   Lamp shape: Small reflector lamps (DLS)

MV
   Mains-Voltage (230 V)

NDLS
   Non-Directional Light Source (light not concentrated in a beam)

PAR
   Lamp shape: Parabolic reflector lamp (DLS)

QMH
   MH-lamp with quartz technology

R
   Lamp shape: Reflector lamp (DLS)

R7s
   Cap-type, with thick pin at each extremity of a tube-shaped lamp

 

1.Introduction to MELISA

The scenario analysis for this Impact Assessment has been performed using the ‘Model for European Light Sources Analysis’ (MELISA). This model was developed during the Ecodesign preparatory study on Light Sources (ENER Lot 8/9/19)
[14](#footnote14)
.

MELISA has been developed on request of the European Commission with the aim to harmonize the data for the two related preparatory studies on lighting, i.e. the ENER Lot 8/9/19 study on Light Sources (concluded in October 2015 and basis for this Impact Assessment) and the ENER Lot 37 on Lighting Systems (concluded in December 2016).

A detailed description of the October 2015 version of MELISA can be found in the Task 7 report of the Light Sources study
[15](#footnote15)
. The input data for the model (e.g. annual sales volumes, average luminous flux, power and efficacy, light source prices, etc.) have been extensively checked against other data sources
[16](#footnote16)
 and discussed with stakeholders.

The model validation, and the interaction with stakeholders, continued during the Impact Assessment study. In July 2016 this resulted in an updated MELISA version, incorporating new input data supplied by industry association LightingEurope
[17](#footnote17)
, and implementing an enhanced method to compute the installed stock of light sources from the annual sales and (variable) lifetimes. The updated version was extensively checked by industry and generally appreciated and accepted.

A further update was performed in October 2017, in particular as regards the projections for the development of average LED efficacy and price. The projection curves were adapted to match the average LED efficacy derived from 2015-2017 catalogue data and taking into account recent projections from UNEP and US DoE 
[18](#footnote18)
. A separate projection curve was created for directional lamps. In addition, electricity rates were updated from Eurostat data.

The updated MELISA version of October 2017 has been used for this Impact Assessment on Light Sources. The July 2016 version was used for the scenario analysis in the Lighting Systems study
[19](#footnote19)
 (using a dedicated model extension), thus ensuring compatibility of data and methods between the two related studies (except for the October 2017 updates), and avoiding double counting of energy savings.

MELISA distinguishes the light source base cases presented in 
[Table 21](#_Ref462143388)
. There are five groups of light source types:

−Linear Fluorescent Lamps (LFL),

−High-Intensity Discharge lamps (HID-lamps),

−Compact Fluorescent Lamps without integrated ballast (CFLni),

−Directional lamps (DLS) and

−Non-directional lamps (NDLS).

As shown in the table, each group is further subdivided in classical technology base cases and also has two associated LED base cases, respectively for LED retrofit lamps and integrated LED luminaires. The shift in (light source) sales from the classical technology base cases to the LED base cases of the same group is one of the essential elements in the scenario projections in MELISA.

Although not shown in 
[Table 21](#_Ref462143388)
, all data in MELISA (both input data and calculated results) are subdivided in those related to the residential sector and those related to the non-residential sector.

MELISA derives the installed stock of light sources in the EU-28 from data on the annual sales and on the average useful lifetimes. These stock data are combined with average unit power values (W) and average annual operating hours per unit (h/a) to compute the total electricity consumption per base case (TWh/a). The contributions of the various base cases are summed to get the EU-28 totals per sector (residential, non-residential) and the sum of the latter two provides the overall EU-28 total for all sectors.

Greenhouse gas (GHG) emissions are directly related to electricity consumption by means of the Global Warming Potential (GWP) for electricity.

The electricity consumption is multiplied by the electricity rates (EUR/kWh)
[20](#footnote20)
 to compute the associated annual electricity costs (billion EUR per year). These are combined with the annual maintenance costs to obtain the total annual running costs.

Multiplying the annual sales by unit prices per light source provides the purchase costs (per base case, per sector, and the overall EU-28 total). Adding the installation costs provides the total acquisition costs.

The sum of acquisition costs and running costs is the total consumer expense.

A survey of the main input variables and the calculated intermediate and final results for MELISA is provided in 
[Table 22](#_Ref436124420)
. For further details see the Light Sources study114, in particular Task 2 (sales, stock), Task 3 (light source usage parameters), Task 4 (summary of input data per base case) and Task 7 reports.

For the residential sector the data are considered to be fairly accurate, within a maximum estimated error of 10%. For the non-residential sector some data could have a larger error, in particular the average annual operating hours for LFLs, the sales volumes of HID-lamps, and the useful lifetimes for non-residential lamps.

The MELISA model has been specifically developed and paid for by the Commission (DG ENER) and is thus subject to the same intellectual property provisions as other contract work for the Commission.

Table 21 Light source base cases distinguished in the MELISA model. The shift in sales from classical technology base cases (on the left) to LED base cases (on the right) is one of the main mechanisms in the MELISA scenarios.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47002.jpg)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47003.jpg)

Table 22 MELISA input data and calculated intermediate and final results (for every base case, for the residential and the non-residential sector)\*.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47004.jpg)

\*For the formulas used in the calculations, see the Task 2 and 7 reports of the Lot 8/9/19 preparatory study.

2.Basic functional parameters

2.1.Basic functional parameters for non-LED base cases

[Table 23](#_Ref462143782)
 shows the luminous flux, power, efficacy, lifetime, annual operating hours and control gear efficiencies used in MELISA for the non-LED base cases. The values shown are sales average values for 2016. For some lamp types and some parameters the values may vary with the years (in particular before 2016). In some cases values might also differ between residential and non-residential sector. For details see the MELISA Excel file.

For non-LED light sources the efficacy is assumed to remain constant over the period 2016-2030, and the same values apply in all scenarios. The effect of Ecodesign measures is not an increase in the efficacy of classical technology lamps, but an acceleration of the shift in sales from these classical models to more efficient LED lighting products. Energy Labelling measures are assumed to affect only average LED efficacy.

[Table 24](#_Ref462146563)
 shows purchase prices, installation costs and repair & maintenance costs for non-LED light sources. All cost information is in fixed 2010 EUR, incl. 20% VAT for residential users and excl. VAT for non-residential. For residential users, no installation and maintenance costs have been considered. Only light source costs have been taken into account; additional luminaire costs are excluded. The economic non-LED light source data remain constant over the 2016-2030 period and the same values apply in all scenarios.

  

|  |  |  |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Table 23 Basic functional non-LED light source parameters used in MELISA in year 2016 | | | | | | | | | | | | |
| Base Case0 | | Flux1 | | Power1 | | Efficacy1 | | Lifetime1 | Hours RES2 | | Hours NRES2 | CG eff3 |
|  | | lm | | W | | lm/W | | H | h/a | | h/a | % |
|  | |  | |  | |  | |  |  | |  |  |
| LFL T12 | | 2450 | | 35 | | 70 | | 8000 | 700 | | 2200 | 80% |
| LFL T8h (halo-phosphor) | | 2400 | | 32 | | 75 | | 8000 | 700 | | 2200 | 80% |
| LFL T8t (tri-phosphor) | | 3320 | | 39 | | 85 | | 21360 | 700 | | 2200 | 88% |
| LFL T5 (13-80 W) | | 2600 | | 28 | | 93 | | 23140 | 700 | | 2200 | 89% |
| LFL X (other LFL) | | 1032 | | 12 | | 86 | | 11000 | 700 | | 2200 | 88% |
|  | |  | |  | |  | |  |  | |  |  |
| HPM (High-Pressure Mercury) | | 10000 | | 208 | | 48 | | 8000 | 700 | | 4000 | 88% |
| HPS (High-Pressure Sodium) | | 20000 | | 182 | | 110 | | 21360 | 700 | | 4000 | 89% |
| MH (Metal-Halide) | | 10000 | | 109 | | 92 | | 14240 | 700 | | 4000 | 89% |
|  | |  | |  | |  | |  |  | |  |  |
| CFLni (without control gear) | | 690 | | 11 | | 65 | | 10000 | 700 | | 1600 | 85% |
|  | |  | |  | |  | |  |  | |  |  |
| HL LV R | | 560 | | 35 | | 16 | | 2000 | 450 | | 450 | 94% |
| HL MV X (DLS) | | 360 | | 50 | | 7 | | 1500 | 450 | | 450 | 100% |
| GLS R (DLS) | | 324 | | 54 | | 6 | | 1000 | 450 | | 450 | 100% |
|  | |  | |  | |  | |  |  | |  |  |
| CFLi (integrated control gear) | | 605 | | 11 | | 55 | | 6000 | 500 | | 500 | 100% |
| HL MV E (NDLS) | | 504 | | 36 | | 14 | | 1500 | 450 | | 450 | 100% |
| GLS X (NDLS) | | 495 | | 45 | | 11 | | 1000 | 450 | | 450 | 100% |
| HL LV C (capsule) | | 515 | | 30 | | 17 | | 2000 | 450 | | 450 | 94% |
| HL MV C (capsule) | | 525 | | 37 | | 14 | | 1500 | 450 | | 450 | 100% |
| HL MV L (linear, R7s) | | 3800 | | 200 | | 19 | | 1000 | 450 | | 450 | 100% |
| 0 For further explanation of the base cases see  [Table 21](#_Ref462143388)  or the Lot 8/9/19 preparatory study  1 Average value for sales in 2016. For other years value may differ. In some cases there are differences between residential and non-residential values. For details see the MELISA Excel file.  2 RES=residential users; NRES=non-residential users. The hours in MELISA are full-power equivalent annual operating hours. E.g. if a light source on average burns 1000 h/a at full power and 500 h/a dimmed at half power, the full-power equivalent hours are 1000+500/2=1250 h/a.  3 Control gear efficiency. A value of 100% indicates that no external control gear is used. In the model, values typically vary with the years; the value shown is the average of sales in 2016. | | | | | | | | | | | | |
| Table 24 Economic data for non-LED light sources used in MELISA in fixed 2010 EUR, incl. 20% VAT for residential (RES), excl. VAT for non-residential (NRES). For residential users, zero installation and maintenance costs are assumed. | | | | | | | | | |
| Base Case | Price RES | | Price NRES | | Installation cost NRES | | Maintenance cost NRES | | |
|  | EUR | | EUR | | EUR | | EUR/year | | |
|  |  | |  | |  | |  | | |
| LFL T12 | 10.10 | | 8.42 | | 6.17 | | 0.46 | | |
| LFL T8h (halo-phosphor) | 10.10 | | 8.42 | | 6.17 | | 0.46 | | |
| LFL T8t (tri-phosphor) | 10.10 | | 8.42 | | 6.17 | | 0.46 | | |
| LFL T5 (13-80 W) | 9.50 | | 7.92 | | 6.17 | | 0.46 | | |
| LFL X (other LFL) | 9.50 | | 7.92 | | 6.17 | | 0.46 | | |
|  |  | |  | |  | |  | | |
| HPM (High-Pressure Mercury) | 20.40 | | 17.00 | | 9.25 | | 6.17 | | |
| HPS (High-Pressure Sodium) | 32.40 | | 27.00 | | 9.25 | | 6.17 | | |
| MH (Metal-Halide) | 32.40 | | 27.00 | | 9.25 | | 6.17 | | |
|  |  | |  | |  | |  | | |
| CFLni (without control gear) | 5.27 | | 4.39 | | 6.17 | | 3.08 | | |
|  |  | |  | |  | |  | | |
| HL LV R | 3.79 | | 3.16 | | 1.85 | | 0.93 | | |
| HL MV X (DLS) | 6.00 | | 5.00 | | 1.85 | | 0.93 | | |
| GLS R (DLS) | 1.37 | | 1.14 | | 1.85 | | 0.93 | | |
|  |  | |  | |  | |  | | |
| CFLi (integrated control gear) | 5.27 | | 4.39 | | 1.85 | | 0.93 | | |
| HL MV E (NDLS) | 2.63 | | 2.19 | | 1.85 | | 0.93 | | |
| GLS X (NDLS) | 0.84 | | 0.70 | | 1.85 | | 0.93 | | |
| HL LV C (capsule) | 3.16 | | 2.63 | | 1.85 | | 0.93 | | |
| HL MV C (capsule) | 3.79 | | 3.16 | | 1.85 | | 0.93 | | |
| HL MV L (linear, R7s) | 3.16 | | 2.63 | | 1.85 | | 0.93 | | |

2.2.LED efficacy and price projections

One of the main scenario mechanisms in MELISA is the shift in sales from classical technology light sources to LED lighting products. As shown in 
[Table 21](#_Ref462143388)
, five groups of LEDs are distinguished in MELISA, respectively for substitution of LFL, HID-lamps, CFLni, DLS and NDLS. For each group, two product variants are distinguished: retrofit LED lamps and (light sources in) integrated LED luminaires
[21](#footnote21)
.

In MELISA, LED products inherit the luminous flux and the annual operating hours from the classical lamps they replace, but multiplied by a rebound factor
[22](#footnote22)
.

The useful lifetime for LEDs has been chosen conservatively 20,000 hours, except for LEDs substituting LFL or HID in the non-residential sector, where 40,000 hours has been used.

In the residential sector, where annual operating hours are 450-700 h/a, this implies lifetimes from 30 to 40 years, i.e. LEDs bought after 2017 will never be replaced within the 2030 time-horizon of the model.

In the non-residential sector, where annual operating hours are 1600-4000 h/a, it implies lifetimes from 10 to 25 years, i.e. LEDs bought after 2017 will at maximum be replaced once within the 2030 time-horizon of the model.

MELISA assumes that between 2017 and 2030 the energy efficacy of the LED light sources will continue to increase, while prices will continue to come down. The projection curves were updated in October 2017 to match the average LED efficacy derived from 2015-2017 catalogue data and taking into account recent projections from UNEP and US DoE 118. A separate projection curve was created for directional lamps. The projection curves presented below are therefore slightly different from those reported in the Lot 8/9/19 study.

Three sets of projection curves are used in the model, respectively for:

-low-end non-directional (NDLS) LED,

-low-end directional (DLS) LED,

-high-end LED.

High-End LED products are those substituting LFL, HID, CFLni in the non-residential sector (‘professional’, high annual operating hours). Low-End LED products are those substituting GLS, HL, CFLi in any sector, and LFL and CFLni in the residential sector (‘consumer’, low annual operating hours).

For each set there are two variant curves for the average efficacy projection:

-BAU, expected development if no new measures are taken

-EL, expected development if new Energy Labelling measures are taken, used in the ELOnly, ECOEL2021 and ECOEL2tiers scenarios.

The EL curves shown in the graphs below assume an introduction of the new labelling scheme in 2020. For an introduction in 2021, as assumed in the most recent analyses, the curve is shifted to the right by one year.

The average efficacies in these projections are in terms of total flux divided by mains power input. Total flux is also used for directional lamps (flux in cone assumed to be 85% of total flux). The reference to mains power implies that control gear efficacy is included in the reported LED efficacy.

Each efficacy projection curve has a corresponding price projection curve, where the price is expressed in EUR per 1000 lm of light output (EUR/klm). The price is in fixed 2010 EUR, excl. VAT and incl. control gear. Installation costs are not included.

The lowest curve leads to a price of EUR 4 / klm in 2030 and is assumed to be valid for the efficacies of low-end NDLS LED in the BAU scenario (122 lm/W in 2030). This curve was agreed with industry during the Lot 8/9/19 study.

The highest curve leads to a price of EUR 8 / klm in 2030 and is assumed to be valid for the efficacies of high-end NDLS LED in all scenarios except BAU (190 lm/W in 2030). This curve is based on information from industry during the Lot 8/9/19 study, that prices for higher efficacy ‘professional lamps’ will be approximately double the prices for lower efficacy ‘consumer lamps’.

For other NDLS efficacies, prices are interpolated between the EUR 4 and EUR 8 curves in function of efficacy. For DLS, that use the (smaller) flux in a cone in the MELISA model and in general have lower efficacies than NDLS, the price curve was set 25% higher than the NDLS curve (based on information gathered during the Lot 8/9/19 study), leading to EUR 5 / klm in 2030 in the BAU scenario (101 lm/W in 2030).

For LED luminaires the projections cover only the efficacy and price of the contained light sources, not of the entire luminaire. Additional luminaire costs or luminaire efficacy losses are not considered
[23](#footnote23)
.

In addition to the projection curves for efficacy and price there are also projection curves for control gear efficiency. These are used only to enable a subdivision between light source energy and control gear energy in the model, where applicable. The control gear efficiencies vary from 85% in 2020 to 90-96% in 2030 (90% for low-end in BAU; 96% for high-end in other scenarios). No graphs are presented here; for details see the MELISA Excel file.

Projections for low-end NDLS (see graphs below):

The solid blue curve indicates the efficacy projection for the BAU scenario, leading to 122 lm/W in 2030. The dashed blue curve (EL) gives the efficacy projection for the other scenarios, 160 lm/W in 2030. The assumed effect of energy labelling is 38 lm/W in 2030, approximately 1.5 label class widths of 25 lm/W.

For comparison, the UNEP/US DoE curves for the same lamp types are shown. They lead to the same 122 lm/W in 2030.

The vertical lines near year 2017 indicate the efficacies for different lamp types as gathered during the Lot 8/9/19 study and this Impact Assessment study (2015-2017 data). For each line the large dot is the average efficacy, the solid line indicates the 25% and 75% percentiles, and the dotted lines indicate the minimum and maximum efficacies encountered.

Corresponding price curves lead to EUR 4 /klm in 2030 for the BAU projection and EUR 6.24 /klm in 2030 for the other scenarios.

For the purposes of estimating the distribution of light source models over the proposed energy efficiency classes in 2020 and 2030, the following efficacy increases with respect to 2017 catalogue data have been assumed:

+7.2% in 2020
   
   

+27.2% in 2030
   

+67% in 2030 with effective label

EL

BAU

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47005.jpg)

EL

BAU

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47006.jpg)

Figure 10 Average sales-efficacy and -prices of low-end NDLS LED light sources (incl. control gear). (for introduction in 2021, shift the EL curve one year to the right)

Projections for low-end DLS (see graphs below):

The solid blue curve indicates the efficacy projection for the BAU scenario, leading to 101 lm/W in 2030. The dashed blue curve (EL) gives the efficacy projection for the other scenarios, 130 lm/W in 2030. The assumed effect of energy labelling (if fully effective) is 29 lm/W in 2030, slightly more than 1 label class width of 25 lm/W. These efficacies consider total flux.

For comparison, the UNEP/US DoE curves for the same lamp types are shown. The MELISA curve has been taken identical to the UNEP curve for ‘downlight track large’.

The vertical lines near year 2017 indicate the efficacies for different lamp types as gathered during the Lot 8/9/19 study and this Impact Assessment study (2015-2017 data). For each line the large dot is the average efficacy, the solid line indicates the 25% and 75% percentiles, and the dotted lines indicate the minimum and maximum efficacies encountered.

Corresponding price curves lead to EUR 5 /klm in 2030 for the BAU projection and EUR 7.86 /klm in 2030 for the other scenarios. Prices assumed to be valid for flux in a cone.

For the purposes of estimating the distribution of light source models over the proposed energy efficiency classes in 2020 and 2030, the following efficacy increases with respect to 2017 catalogue data have been assumed:

+7.2% in 2020
   
   +34% in 2030
   
   +74% in 2030 with effective label

BAU

EL

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47007.jpg)

EL

BAU

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47008.jpg)

Figure 11 Average sales-efficacy and -prices of low-end DLS LED light sources (incl. control gear). (for introduction in 2021, shift the ECOEL2021 curve one year to the right)

Projections for high-end LED (see graphs below):

The solid blue curve indicates the efficacy projection for the BAU scenario, leading to 174 lm/W in 2030. The dashed blue curve (EL) gives the efficacy projection for the other scenarios, 190 lm/W in 2030. The assumed effect of energy labelling (if fully effective) is 16 lm/W in 2030, approximately 2/3 label class width of 25 lm/W.

For comparison, the UNEP/US DoE curves for the same lamp types are shown.

The vertical line near year 2017 indicates the efficacies for LED tubes as gathered during the Lot 8/9/19 study and this Impact Assessment study (2015-2017 data). The large dot is the average efficacy, the solid line indicates the 25% and 75% percentiles, and the dotted line indicates the minimum and maximum efficacies encountered.

Corresponding price curves lead to EUR 7.03 /klm in 2030 for the BAU projection and EUR 8 /klm in 2030 for the other scenarios.

For the purposes of estimating the distribution of light source models over the proposed energy efficiency classes in 2020 and 2030, the following efficacy increases with respect to 2017 catalogue data have been assumed:

+12% in 2020
   
   +55% in 2030
   
   +70% in 2030 with effective label

EL

BAU

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47009.jpg)

BAU

EL

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47010.jpg)

Figure 12 Average sales-efficacy and -prices of high-end LED light sources (incl. control gear). (for introduction in 2021, shift the ECOEL2021 curve one year to the right)

3.General input parameters

3.1.Price shares per business sector

For purposes of computation of light source revenues for industry, wholesale, retail and government, these sectors are assigned a share of the light source price as specified below.

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Table 25 Shares of light source prices assigned to a business sector for purposes of revenue computation per sector | | | | |
| Base Case | Industry | Wholesale | Retail | VAT |
|  |  |  |  |  |
| Non-Residential, LFL, HID and LED | 80% | 10% | 10% | 0% |
| Non-Residential, all other lamp types | 46% | 30% | 24% | 0% |
|  |  |  |  |  |
| Residential, LFL, HID and LED | 66% | 10% | 7% | 17% |
| Residential, all other lamp types | 38% | 23% | 22% | 17% |

3.2.Electricity rates

[Table 26](#_Ref427673918)
 shows the electricity prices applied in MELISA. The prices are in EUR/kWh, in fixed EUR at year 2010. For the residential sector they include 20% VAT.

Electricity prices for the years 1990-2016 are based on Eurostat data 
[24](#footnote24)
. For later years an escalation rate of 4% has been applied (following the MEErP). The values shown in the table are not discounted (and no discounting is applied elsewhere in the scenario analysis).

|  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Table 26 Electricity prices used in the scenario analyses, in EUR/kWh, fixed EUR at year 2010. Residential values include 20% VAT; non-residential values exclude VAT. (Escalation rate 4% after 2016, from MEErP, not discounted) | | | | | | | | | |
| Residential prices, incl. VAT | | | | | | | | | |
| 1990 | 1995 | 2000 | 2005 | 2010 | 2015 | 2016 | 2020 | 2025 | 2030 |
| 0.178 | 0.181 | 0.162 | 0.153 | 0.170 | 0.209 | 0.205 | 0.240 | 0.292 | 0.355 |
| Non-residential prices, excl. VAT | | | | | | | | | |
| 1990 | 1995 | 2000 | 2005 | 2010 | 2015 | 2016 | 2020 | 2025 | 2030 |
| 0.119 | 0.103 | 0.084 | 0.087 | 0.106 | 0.120 | 0.115 | 0.135 | 0.164 | 0.200 |

In sensitivity analyses, the effect of lower electricity rates was examined by applying the projected rates from the PRIMES model
[25](#footnote25)
. For the residential sector PRIMES-rates were used as supplied; for the non-residential sector, based on data from the Ecodesign Impact Accounting, a weighted-average electricity rate was applied, assuming that 80% of the lighting electricity is consumed in the tertiary sector and 20% in industry. These PRIMES’ electricity rates are shown in 
[Table 27](#_Ref512266250)
.

|  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Table 27 Electricity prices used in the sensitivity analyses, in EUR/kWh. These rates derive from the PRIMES model. Non-residential prices assume 80% tertiary sector and 20% industry. | | | | | | | | | |
| Residential prices, incl. VAT | | | | | | | | | |
| 1990 | 1995 | 2000 | 2005 | 2010 | 2015 | 2016 | 2020 | 2025 | 2030 |
| 0.178 | 0.181 | 0.162 | 0.156 | 0.172 | 0.190 | 0.192 | 0.203 | 0.209 | 0.212 |
| Non-residential prices, excl. VAT | | | | | | | | | |
| 1990 | 1995 | 2000 | 2005 | 2010 | 2015 | 2016 | 2020 | 2025 | 2030 |
| 0.155 | 0.134 | 0.109 | 0.118 | 0.138 | 0.144 | 0.147 | 0.156 | 0.160 | 0.163 |

3.3.Global Warming Potential

Greenhouse gas (GHG-) emissions are expressed in MtCO2eq
[26](#footnote26)
 and obtained directly from the electricity consumption, multiplying by the Global Warming Potential (GWP) for electricity. The GWP values defined in MELISA (and also used in the Ecodesign Impact Accounting) are assumed to decrease over the years: e.g. 0.395 kgCO2eq/kWh in 2015, 0.380 in 2020, 0.360 in 2025, 0.340 in 2030 
[27](#footnote27)
.

4.BAU-scenario

4.1.BAU-scenario assumptions

The Business-as-Usual (BAU) scenario that is used as reference for the computation of savings is the same as described in the Lot 8/9/19 Task 7 report114.

The BAU-scenario assumes that no new ecodesign or energy labelling regulations will be introduced for light sources, but takes into account all measures of existing Regulations 244/2009, 245/2009 and 1194/2012, including those that still have to take effect in 2016-2018 (phase-out of mains-voltage directional halogen lamps in 2016, more severe requirements for metal-halide lamps in 2017, phase-out of many non-directional halogen lamps in 2018).

In addition, considering current trends and future expectations, the BAU-scenario assumes that a shift in sales from classical lighting technologies to LED lighting products (retrofit lamps or light sources in integrated luminaires) will anyway take place, also without new regulation. The assumed speed of this shift is indicated in 
[Table 28](#_Ref432862852)
.

Table 28: Percentage of the potential sales (replacements and new sales) for a non-LED base case technology that is assumed to shift to LED products (retrofit or luminaire) in the BAU scenario for years 2015, 2020, 2025 and 2030.

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Base Case | 2015 | 2020 | 2025 | 2030 |
| LFL T8 & T12 [28](#footnote28) | 5 | 20 | 40 | 60 |
| LFL T5 | 0 | 10 | 40 | 60 |
| LFL X | 0 | 10 | 40 | 60 |
| HPS | 6 | 18 | 40 | 60 |
| MH | 18 | 20 | 40 | 60 |
| CFLni | 15 | 40 | 60 | 80 |
| CFLi (NDLS) | 25 | 80 | 90 | 90 |
| HL LV R (DLS) | 15 | 30 | 50 | 70 |
| HL LV C (NDLS) | 10 | 50 | 70 | 90 |
| HL MV C (G9, NDLS) | 10 | 50 | 70 | 90 |
| HL MV L (R7s, NDLS) | 10 | 50 | 70 | 90 |
| HPM | 42 | 99 | 100 | |
| HL MV E (NDLS) | 15 | 90 | 100 | |
| HL MV X (DLS) | 30 | 100 | | |
| GLS R (DLS) | 50 | 100 | | |
| GLS X (NDLS) | 30 | 100 | | |

Considering current trends and future expectations, the BAU-scenario also assumes that between 2017 and 2030 the energy efficacy of the LED light sources will continue to increase, while prices will continue to come down (see section on basic functional parameters for LEDs).

Consequently, the BAU scenario is not at all a freeze scenario, but already includes expectations on the future development of the light sources market, and already leads to energy savings with respect to a scenario that freezes the current situation.

4.2.BAU-scenario, Sales

Light source sales quantities for the BAU-scenario are reported below in million units. The graph clearly shows the phase-out of legacy incandescent lamps (GLS, purple area) between 2009 and 2013, the phase-out of the majority of halogen lamps (Tungsten-HL, green area) between 2016 and 2018, and the reduction of CFL popularity after 2010. In addition, starting from about 2014, the increase in sales of LEDs is evident.

The light purple and light green areas, indicated as GLS and HL ‘from storage’, are not real sales but represent lamps that are installed by mainly residential users from the supplies they had in house. These are lamps bought in previous years and are not counted (again) as sales in the model in the years where they ‘appear’, but they are taken into account for stock calculations.

In general, from 2008, there is a strong decrease in sales quantities. This is due to lamps with (much) longer lifetimes (first CFL, later LED) replacing lamps with short lifetimes (GLS, HL).

|  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Table 29: BAU-scenario, annual light source sales volumes in million units | | | | | | | |
| EU-28 SALES | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 269 | 390 | 285 | 236 | 154 | 98 |
| CFL | 51 | 567 | 220 | 151 | 58 | 25 |
| Tungsten-HL | 88 | 650 | 738 | 200 | 66 | 13 |
| GLS | 1688 | 697 | 58 | 0 | 0 | 0 |
| HID | 17 | 41 | 28 | 17 | 11 | 4 |
| LED | 0 | 8 | 372 | 1133 | 641 | 597 |
| GLS from Storage | 0 | 112 | 187 | 0 | 0 | 0 |
| HL from Storage | 0 | 90 | 124 | 10 | 0 | 0 |
| TOTAL (excl. from Storage) | 2112 | 2353 | 1702 | 1737 | 929 | 737 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47011.jpg)

4.3.BAU-scenario, Stock

The installed stock of light sources in EU-28 for the BAU-scenario is reported below in million units. The quantity of installed light sources shows a continuous increase since 1990 and this trend is expected to continue. The growth rate after 2016 is between 1.18%/a and 0.86%/a for the residential sector (increase in number of households and in number of lamps per household) and 2.5%/a for the non-residential sector (based on GDP annual growth rate).

The graph clearly shows that, from about 2008, CFL (red area) and Halogen lamps (green area) are substituting the legacy incandescent lamps (GLS, purple area) phased-out by the 2009 Ecodesign regulation. Starting from 2014, LED products are increasingly substituting CFL and Halogen lamps and this trend is expected to continue in the BAU-scenario, also without new Ecodesign measures.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 30: BAU-scenario, installed stock of light sources in million units | | | | | | |
| EU-28 STOCK | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 1232 | 2008 | 2210 | 2264 | 2115 | 1685 |
| CFL | 326 | 3684 | 4576 | 3604 | 1734 | 879 |
| Tungsten-HL | 284 | 2043 | 2657 | 1240 | 394 | 116 |
| GLS | 3694 | 1923 | 193 | 1 | 0 | 0 |
| HID | 40 | 95 | 91 | 79 | 57 | 29 |
| LED | 0 | 14 | 745 | 5138 | 9192 | 11926 |
| GLS from Storage | 0 | 187 | 471 | 6 | 0 | 0 |
| HL from Storage | 0 | 90 | 417 | 126 | 0 | 0 |
| TOTAL (excl. from Storage) | 5576 | 10045 | 11360 | 12459 | 13492 | 14635 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47012.jpg)

4.4.BAU-scenario, Electricity

The tables and graph in this section show the total EU-28 electricity consumption by light sources in the BAU-scenario
[29](#footnote29)
.

In 2015 the EU-28 electricity consumption for lighting was 336 TWh/a, covering 12.4% of the overall EU-28 electricity use 
[30](#footnote30)
. The primary energy necessary to generate and distribute this electricity was 72 Mtoe, covering 4.5% of the EU-28 Gross Inland Consumption of energy 
[31](#footnote31)
.

In the BAU-scenario the electricity for lighting is expected to decrease to 299 TWh/a in 2030 (-12% vs. 2015), notwithstanding a 25% increase in the quantity of installed light sources (see previous section). This decrease is due to the increased use of high-efficacy LED products.

In 2015, the largest part is consumed in the non-residential sector (253 TWh, 75%), mainly by LFL-applications (161 TWh/a, 48%, e.g. offices), HID-applications (69 TWh/a, 20%, e.g. road lighting) and some by CFLni-applications (10 TWh/a, 3%). Other non-directional applications (mainly residential) consume 72 TWh/a (21%) and directional applications 24 TWh/a (7%).

In 2015, 96% of the electricity (321 TWh/a) is consumed by classical (non-LED) lighting technologies. In 2030 this is expected to drop to 51% (152 TWh/a). 
[Table 32](#_Ref460939884)
 also shows the cumulative electricity uses over the period 2015-2030.

The electricity consumption data for the BAU-scenario clearly indicates the importance of LFL- and HID-applications, and in particular the high contribution (approximately one-third of the total) of LFL T8 tri-phosphor.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 31: BAU-scenario, EU-28 total Electricity consumption by light sources. Includes control gear energy. Excluded: controls, special purpose lamps, standby. | | | | | | |
| EU-28 ELECTRICITY | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 91 | 136 | 159 | 169 | 158 | 124 |
| CFL | 3 | 25 | 30 | 24 | 13 | 6 |
| Tungsten-HL | 8 | 46 | 52 | 23 | 7 | 2 |
| GLS | 90 | 46 | 4 | 0 | 0 | 0 |
| HID | 34 | 69 | 59 | 50 | 37 | 20 |
| LED | 0 | 0 | 15 | 51 | 98 | 147 |
| GLS from Storage | 0 | 4 | 10 | 0 | 0 | 0 |
| HL from Storage | 0 | 1 | 7 | 2 | 0 | 0 |
| TOTAL (excl. from Storage) | 225 | 328 | 336 | 320 | 312 | 299 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47013.jpg)

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 32 BAU-scenario, EU-28 Total Electricity Consumption for Lighting, in TWh/a or TWh cumulative). Includes electricity for light sources and control gears. Does not include electricity for control devices, special purpose lamps and during stand-by. | | | | | | |
|  | 1990 | 2015 | 2020 | 2025 | 2030 | cumulative  2015-2030 |
| Total EU-28, all sectors | 225 | 336 | 320 | 312 | 299 | 5079 |
| total Residential (RES) | 83 | 82 | 49 | 37 | 34 | 772 |
| total Non-Residential (NRES) | 142 | 253 | 271 | 276 | 265 | 4307 |
| total Classic Technology | 225 | 321 | 269 | 215 | 152 | 3855 |
| total LED | 0 | 15 | 51 | 98 | 147 | 1224 |
|  |  |  |  |  |  |  |
| LFL T8t | 32 | 117 | 124 | 115 | 90 | 1838 |
| LFL T5 (13-80 W) | 0 | 35 | 42 | 40 | 32 | 620 |
| other LFL | 59 | 6 | 3 | 2 | 1 | 48 |
| LED in former LFL-applications | 0 | 2 | 13 | 34 | 64 | 425 |
| Total LFL-applications | 91 | 161 | 182 | 192 | 188 | 2930 |
| HPM | 16 | 4 | 0 | 0 | 0 | 6 |
| HPS | 15 | 31 | 31 | 24 | 14 | 416 |
| MH | 3 | 25 | 20 | 13 | 6 | 253 |
| LED in former HID-applications | 0 | 10 | 21 | 33 | 47 | 443 |
| Total HID-applications | 34 | 69 | 71 | 71 | 66 | 1118 |
| CFLni | 2 | 9 | 8 | 5 | 3 | 103 |
| LED in former CFLni-applications | 0 | 0 | 1 | 3 | 4 | 35 |
| Total CFLni-applications | 2 | 10 | 9 | 8 | 7 | 138 |
| HL LV R (MR/AR) (GU4,GU5.3,G53) | 1 | 11 | 9 | 5 | 2 | 111 |
| HL MV (DLS) (GU10 or E-cap) | 0 | 11 | 1 | 0 | 0 | 34 |
| GLS (DLS) | 9 | 1 | 0 | 0 | 0 | 2 |
| LED in DLS-applications | 0 | 1 | 4 | 5 | 6 | 64 |
| Total DLS-applications | 10 | 24 | 13 | 10 | 8 | 210 |
| CFLi | 1 | 21 | 17 | 7 | 4 | 195 |
| HL MV (NDLS, E-cap) | 0 | 24 | 8 | 0 | 0 | 120 |
| GLS (NDLS) | 81 | 13 | 0 | 0 | 0 | 30 |
| HL LV Capsule (G4, GY6.35) | 3 | 3 | 1 | 1 | 0 | 19 |
| HL MV Capsule (G9) | 0 | 3 | 2 | 1 | 0 | 24 |
| HL MV Linear (R7s) | 3 | 7 | 3 | 0 | 0 | 37 |
| LED in NDLS-applications | 0 | 2 | 12 | 22 | 26 | 258 |
| Total NDLS-applications | 88 | 72 | 44 | 31 | 30 | 682 |

4.5.BAU-scenario, GHG-emissions

In 2015 the EU-28 GHG-emission due to use of light sources is estimated 133 MtCO2eq/a (2.8% of the total EU-28 emission
[32](#footnote32)
). In 2030 this is expected to decrease to 102 MtCO2eq/a in the BAU-scenario, due to decreasing electricity consumption for lighting and due to decreasing GWP for electricity.

GHG-emissions have been computed for the electricity consumption of all light sources together, not per light source type. The distribution of the emissions over the types is proportional to the distribution of electricity use in 
[Table 32](#_Ref460939884)
.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 33: BAU-Total EU-28 Greenhouse gas (GHG-) emission due to lighting electricity consumption in MtCO2eq/a or MtCO2eq cumulative | | | | | | |
| MtCO2eq |  | 2015 | 2020 | 2025 | 2030 | cumulative |
| BAU | GHG-emis | 133 | 122 | 112 | 102 | 1878 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47014.jpg)

4.6.BAU-scenario, User Expense for light sources

[Table 34](#_Ref462217767)
, 
[Table 35](#_Ref462217769)
 and 
[Table 36](#_Ref462217771)
 respectively provide the EU-28 total Acquisition costs (purchase and installation), Electricity costs, and total User Expense (including also maintenance costs) for light sources. Corresponding graphs are shown in 
[Figure 13](#_Ref460945664)
.

All costs are in fixed EUR at year 2010 and include VAT for residential users.

Acquisition costs show two peaks. The first one around 2010 is due to investments in Halogen lamps and CFLs to replace the incandescent lamps (GLS) phased-out by the 2009 Ecodesign regulation. The one between 2015 and 2020 is due to investments in LED lighting products, replacing Halogen lamps phased-out by Ecodesign regulations in 2016 and 2018, replacing increasingly unpopular CFLs, replacing some LFL T8 in office lighting, and some HID-lamps in street lighting.

Peak acquisition costs are EUR 17.8 billion in 2016. In later years these costs decrease to EUR 11.0 billion in 2030, due to decreasing sales quantities (
[Table 29](#_Ref462218707)
) and due to LED prices coming down (Annex 5 Section 2.3).

Electricity costs amount to EUR 46 billion in 2016, which is almost three times the acquisition costs in the same year. Electricity costs are expected to continue to increase, reaching EUR 65 billion by 2030. This increase occurs notwithstanding a decrease in electricity consumption (
[Table 31](#_Ref462219404)
) and is due to the increase in electricity rates (
[Table 26](#_Ref427673918)
).

Without the 2015-2020 investments in more efficient LED lighting products, electricity costs would have risen much more: Applying the difference in electricity rates between 2016 and 2030 (factor 1.8 increase) and the difference in stock over the same period (factor 1.25 increase) to the EUR 46 billion electricity costs of 2016, the 2030 electricity costs would have been 46\*1.8\*1.25 = EUR 104 billion instead of the now estimated EUR 65 billion.

As electricity costs are far higher than acquisition costs, the Total User Expense also shows an increasing trend. Details on User Expense are presented in 
[Table 37](#_Ref460947191)
.

In 2015 the EU-28 Total User Expense for lighting was EUR 70 billion, of which EUR46 billion (66%) were spend in the non-residential sector. The expenses for LED light sources (retrofit lamps or light sources in integrated luminaires) in 2015 amounted to EUR 10 billion (14% of total expense). Major expenses were made for LFL-applications (EUR 26 billion, 37%) and NDLS-applications (EUR 22 billion, 31%).

In 2030 Total User Expenses are projected to increase to EUR 83 billion.

  

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 34: BAU-scenario, EU-28 total Acquisition costs for light sources (acquisition and installation), in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. | | | | | | |
| EU-28  ACQUISITION COST | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 3.84 | 5.53 | 4.01 | 3.34 | 2.18 | 1.38 |
| CFL | 0.36 | 3.49 | 1.48 | 1.02 | 0.41 | 0.16 |
| Tungsten-HL | 0.34 | 2.79 | 2.90 | 0.80 | 0.29 | 0.06 |
| GLS | 2.08 | 0.86 | 0.07 | 0.00 | 0.00 | 0.00 |
| HID | 0.52 | 1.44 | 1.02 | 0.62 | 0.38 | 0.15 |
| LED | 0 | 0.29 | 8.05 | 10.34 | 7.69 | 9.04 |
| GLS from Storage | 0 | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.00 | 0.33 | 0.03 | 0.00 | 0.00 |
| TOTAL | 7.15 | 14.40 | 17.86 | 16.14 | 10.95 | 10.79 |

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 35: BAU-scenario, EU-28 total Electricity costs for light sources, in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. See  [Table 26](#_Ref427673918)  for applied electricity rates (from MEErP, incl. escalation 4%/a). | | | | | | |
| EU-28  ELECTRICITY COST | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 11.13 | 14.91 | 19.68 | 23.55 | 26.79 | 25.69 |
| CFL | 0.45 | 3.45 | 4.99 | 4.58 | 2.87 | 1.80 |
| Tungsten-HL | 1.17 | 6.93 | 9.57 | 4.61 | 1.54 | 0.52 |
| GLS | 14.91 | 7.21 | 0.78 | 0.00 | 0.00 | 0.00 |
| HID | 4.02 | 7.29 | 7.09 | 6.81 | 6.14 | 3.92 |
| LED | 0 | 0.03 | 2.01 | 8.21 | 18.62 | 33.10 |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.25 | 1.41 | 0.49 | 0.00 | 0.00 |
| TOTAL | 31.68 | 40.83 | 47.52 | 48.29 | 55.96 | 65.03 |

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 36: BAU-scenario, EU-28 total User Expense for light sources, in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. In addition to Acquisition- and Electricity-costs from previous tables, this also includes maintenance costs for non-residential sector. | | | | | | |
| EU-28  TOTAL USER EXPENSE | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 15.44 | 21.23 | 24.56 | 27.79 | 29.79 | 27.72 |
| CFL | 1.13 | 9.10 | 8.98 | 7.60 | 4.34 | 2.44 |
| Tungsten-HL | 1.64 | 10.34 | 13.19 | 5.84 | 2.01 | 0.64 |
| GLS | 17.68 | 8.43 | 0.88 | 0.00 | 0.00 | 0.00 |
| HID | 4.79 | 9.32 | 8.67 | 7.92 | 6.88 | 4.24 |
| LED | 0 | 0.32 | 10.34 | 20.35 | 30.23 | 47.96 |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.25 | 1.74 | 0.52 | 0.00 | 0.00 |
| TOTAL | 40.68 | 59.74 | 70.36 | 70.05 | 73.26 | 83.00 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47015.jpg)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47016.jpg)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47017.jpg)

Figure 13 BAU-scenario, EU-28 Total Acquisition Cost (top), Electricity Cost (centre) and Total User Expense (bottom) for light sources, in million euros, fixed EUR 2010 incl. residential VAT. Scales for graphs are different. (this uses electricity rates from MEErP with 4%/a escalation, see Section 3.2)

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 37 BAU-scenario, EU-28 Total User Expense for Lighting, in billion euros. Fixed 2010 euros, includes VAT for residential. | | | | | | |
|  | 1990 | 2015 | 2020 | 2025 | 2030 | cumulative  2015-2030 |
| Total EU-28, all sectors | 41 | 70 | 70 | 73 | 83 | 1171 |
| total Residential (RES) | 16 | 24 | 17 | 12 | 13 | 255 |
| total Non-Residential (NRES) | 24 | 46 | 53 | 61 | 70 | 916 |
| total Classic Technology | 41 | 60 | 50 | 43 | 35 | 748 |
| total LED | 0 | 10 | 20 | 30 | 48 | 423 |
|  |  |  |  |  |  |  |
| LFL T8t | 5.1 | 17.8 | 20.0 | 21.6 | 20.1 | 323 |
| LFL T5 (13-80 W) | 0.0 | 5.5 | 6.9 | 7.6 | 7.2 | 111 |
| other LFL | 10.4 | 1.2 | 0.8 | 0.6 | 0.4 | 12 |
| LED in former LFL-applications | 0.0 | 1.3 | 4.4 | 9.5 | 18.9 | 128 |
| Total LFL-applications | 15 | 26 | 32 | 39 | 47 | 574 |
| HPM | 2.2 | 0.5 | 0.0 | 0.0 | 0.0 | 1 |
| HPS | 2.2 | 4.3 | 4.6 | 4.4 | 3.0 | 67 |
| MH | 0.4 | 3.8 | 3.3 | 2.5 | 1.2 | 44 |
| LED in former HID-applications | 0.0 | 3.1 | 4.3 | 7.5 | 12.0 | 103 |
| Total HID-applications | 5 | 12 | 12 | 14 | 16 | 215 |
| CFLni | 0.8 | 3.0 | 2.6 | 1.9 | 1.0 | 35 |
| LED in former CFLni-applications | 0.0 | 0.3 | 1.0 | 1.8 | 2.8 | 23 |
| Total CFLni-applications | 1 | 3 | 4 | 4 | 4 | 58 |
| HL LV R (MR/AR) (GU4,GU5.3,G53) | 0.3 | 2.8 | 2.4 | 1.6 | 0.6 | 30 |
| HL MV (DLS) (GU10 or E-cap) | 0.0 | 2.9 | 0.1 | 0.0 | 0.0 | 9 |
| GLS (DLS) | 1.9 | 0.2 | 0.0 | 0.0 | 0.0 | 0 |
| LED in DLS-applications | 0.0 | 1.5 | 1.6 | 2.0 | 2.7 | 31 |
| Total DLS-applications | 2 | 7 | 4 | 4 | 3 | 70 |
| CFLi | 0.4 | 6.0 | 5.0 | 2.5 | 1.4 | 60 |
| HL MV (NDLS, E-cap) | 0.0 | 6.1 | 2.1 | 0.0 | 0.0 | 30 |
| GLS (NDLS) | 15.8 | 2.7 | 0.0 | 0.0 | 0.0 | 6 |
| HL LV Capsule (G4, GY6.35) | 0.8 | 0.7 | 0.4 | 0.2 | 0.0 | 5 |
| HL MV Capsule (G9) | 0.0 | 0.9 | 0.6 | 0.2 | 0.0 | 7 |
| HL MV Linear (R7s) | 0.6 | 1.5 | 0.7 | 0.1 | 0.0 | 8 |
| LED in NDLS-applications | 0.0 | 4.2 | 9.1 | 9.3 | 11.6 | 137 |
| Total NDLS-applications | 18 | 22 | 18 | 12 | 13 | 254 |

4.7.BAU-scenario, Revenues per business sector

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47018.jpg)

Figure 14 BAU-scenario, EU-28 Total Revenues from light sources per business sector, in million euros, fixed EUR 2010. For assumed price shares per sector, see 
[Table 25](#_Ref462326410)
.

5.ELONLY scenario

5.1.ELONLY scenario, assumptions

In this scenario the new energy labelling A-G scheme is assumed to be introduced in 2021, while no new Ecodesign measures are taken (existing Ecodesign regulations remain valid), so this is a Label-only scenario.

The change in energy labelling is assumed not to affect the shift from traditional lighting technologies to LED products: this shift remains the same as in the BAU-scenario. Consequently sales and stock are the same as reported for the BAU-scenario.

What changes in the ELONLY scenario is the average efficacy of the LED lighting products being sold, and the corresponding average LED light source price. The applied LED efficacies and prices have been explained in Section 2.2, but the graphs presented there are for introduction of the new labelling measures in 2020: shift the curves one year to the right to get those for introduction in 2021. The following tables summarize the data used in the analyses. After 2030 efficacies and prices are assumed to remain constant.

|  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Table 38 LED-efficacies in the ELONLY scenario in total lm / mains W, incl. control gear.  New LBL introduction assumed in 2021. See Section 2.2 for further information | | | | | | | | | |
| lm/W | 2010 | 2012 | 2014 | 2016 | 2018 | 2020 | 2022 | 2025 | 2030 | |
| Low-End NDLS | 26 | 51 | 78 | 91 | 99 | 103 | 118 | 142 | 160 | |
| Low-End DLS | 20 | 41 | 62 | 70 | 76 | 81 | 94 | 114 | 130 | |
| High-End | 26 | 51 | 78 | 102 | 115 | 125 | 139 | 166 | 190 | |

|  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Table 39 LED-prices in the ELONLY scenario in EUR/klm, incl. control gear.  New LBL introduction assumed in 2021. See Section 2.2 for further information | | | | | | | | | |
| EUR/klm | 2010 | 2012 | 2014 | 2016 | 2018 | 2020 | 2022 | 2025 | 2030 | |
| Low-End NDLS | 48.00 | 34.00 | 25.00 | 15.50 | 9.40 | 7.30 | 7.68 | 7.22 | 6.24 | |
| Low-End DLS | 60.00 | 42.50 | 31.25 | 19.38 | 11.75 | 9.13 | 10.24 | 9.40 | 7.86 | |
| High-End | 48.00 | 34.00 | 25.00 | 21.60 | 17.50 | 13.01 | 10.77 | 9.10 | 8.00 | |

5.2.ELONLY scenario, Electricity

Compared to a BAU scenario without changes in energy label regulation, introduction of the new labelling scheme in 2021 saves 4.2 TWh/a of electricity in 2025 and 11.5 TWh/a in 2030.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 40: ELONLY scenario, EU-28 total Electricity consumption by light sources. Includes control gear energy. Excluded: controls, special purpose lamps, standby. | | | | | | |
| EU-28 ELECTRICITY | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 | |
| LFL | 91 | 136 | 159 | 169 | 158 | 124 | |
| CFL | 3 | 25 | 30 | 24 | 13 | 6 | |
| Tungsten-HL | 8 | 46 | 52 | 23 | 7 | 2 | |
| GLS | 90 | 46 | 4 | 0 | 0 | 0 | |
| HID | 34 | 69 | 59 | 50 | 37 | 20 | |
| LED | 0 | 0 | 15 | 51 | 94 | 136 | |
| GLS from Storage | 0 | 4 | 10 | 0 | 0 | 0 | |
| HL from Storage | 0 | 1 | 7 | 2 | 0 | 0 | |
| TOTAL (excl. from Storage) | 225 | 328 | 336 | 320 | 308 | 288 | |
| TOTAL for BAU for comparison | 225 | 328 | 336 | 320 | 312 | 299 | |
| Savings due to ELOnly |  |  |  |  | 4.2 | 11.5 | |

5.3.ELONLY scenario, GHG-emissions

Compared to a BAU scenario without changes in energy label regulation, introduction of the new labelling scheme in 2021 saves 1.5 MtCO2eq/a of GHG-emissions in 2025 and 3.9 MtCO2eq/a in 2030.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 41: ELONLY Total EU-28 Greenhouse gas (GHG-) emission due to lighting electricity consumption in MtCO2eq/a or MtCO2eq cumulative | | | | | | |
| MtCO2eq |  | 2015 | 2020 | 2025 | 2030 | cumulative | |
| ELONLY |  | 133 | 122 | 111 | 98 | 1859 | |
| BAU for comparison |  | 133 | 122 | 112 | 102 | 1878 | |
| Reduction due to ELOnly |  |  |  | 1.5 | 3.9 | 19 | |

5.4.ELONLY scenario, User Expense for light sources

In the ELONLY scenario, acquisition costs are higher than in the BAU scenario: EUR 1.7 billion per year higher in 2025 and 1.5 billion per year in 2030. Users buy the same quantity of LED products as in the BAU scenario, but in the ELONLY scenario these LEDs on average have higher prices, and higher efficacy.

Due to the higher average efficacy, the electricity costs are lower than in the BAU scenario: EUR 0.8 billion per year less in 2025 and EUR 2.6 billion per year in 2030.

The balance of the costs, i.e. the total user-expense for lighting, is negative in 2025 (EUR -0.9 billion per year) where additional acquisition costs (investment) are still dominant, but already positive in 2030 (EUR +1.1 billion per year) where lower electricity costs (payback) are dominant. This positive trend continues even stronger in later years.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 42: ELONLY scenario, EU-28 total Acquisition costs for light sources (purchase and installation), in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. | | | | | | |
| EU-28  ACQUISITION COST | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 3.84 | 5.53 | 4.01 | 3.34 | 2.18 | 1.38 |
| CFL | 0.36 | 3.49 | 1.48 | 1.02 | 0.41 | 0.16 |
| Tungsten-HL | 0.34 | 2.79 | 2.90 | 0.80 | 0.29 | 0.06 |
| GLS | 2.08 | 0.86 | 0.07 | 0.00 | 0.00 | 0.00 |
| HID | 0.52 | 1.44 | 1.02 | 0.62 | 0.38 | 0.15 |
| LED | 0 | 0.29 | 8.05 | 10.34 | 9.35 | 10.52 |
| GLS from Storage | 0 | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.00 | 0.33 | 0.03 | 0.00 | 0.00 |
| TOTAL ELONLY | 7.15 | 14.40 | 17.86 | 16.14 | 12.61 | 12.28 |
| BAU for comparison | 7.15 | 14.40 | 17.86 | 16.14 | 10.95 | 10.79 |
| Additional due to ELOnly |  |  |  |  | 1.7 | 1.5 |

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 43: ELONLY scenario, EU-28 total Electricity costs for light sources, in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. See  [Table 26](#_Ref427673918)  for applied electricity rates (from MEErP, incl. escalation 4%/a). | | | | | | |
| EU-28  ELECTRICITY COST | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 11.13 | 14.91 | 19.68 | 23.55 | 26.79 | 25.69 |
| CFL | 0.45 | 3.45 | 4.99 | 4.58 | 2.87 | 1.80 |
| Tungsten-HL | 1.17 | 6.93 | 9.57 | 4.61 | 1.54 | 0.52 |
| GLS | 14.91 | 7.21 | 0.78 | 0.00 | 0.00 | 0.00 |
| HID | 4.02 | 7.29 | 7.09 | 6.81 | 6.14 | 3.92 |
| LED | 0 | 0.03 | 2.01 | 8.21 | 17.83 | 30.54 |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.25 | 1.41 | 0.49 | 0.00 | 0.00 |
| TOTAL ELONLY | 31.68 | 40.83 | 47.52 | 48.29 | 55.17 | 62.46 |
| BAU for comparison | 31.68 | 40.83 | 47.52 | 48.29 | 55.96 | 65.03 |
| Saving due to ELOnly |  |  |  |  | 0.8 | 2.6 |

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 44: ELONLY scenario, EU-28 total User Expense for light sources, in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. In addition to Acquisition- and Electricity-costs from previous tables, this also includes maintenance costs for non-residential sector. | | | | | | |
| EU-28  TOTAL USER EXPENSE | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 15.44 | 21.23 | 24.56 | 27.79 | 29.79 | 27.72 |
| CFL | 1.13 | 9.10 | 8.98 | 7.60 | 4.34 | 2.44 |
| Tungsten-HL | 1.64 | 10.34 | 13.19 | 5.84 | 2.01 | 0.64 |
| GLS | 17.68 | 8.43 | 0.88 | 0.00 | 0.00 | 0.00 |
| HID | 4.79 | 9.32 | 8.67 | 7.92 | 6.88 | 4.24 |
| LED | 0 | 0.32 | 10.34 | 20.35 | 31.10 | 46.88 |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.25 | 1.74 | 0.52 | 0.00 | 0.00 |
| TOTAL ELONLY | 40.68 | 59.74 | 70.36 | 70.05 | 74.12 | 81.92 |
| BAU for comparison | 40.68 | 59.74 | 70.36 | 70.05 | 73.26 | 83.00 |
| Saving due to ELOnly |  |  |  |  | -0.9 | +1.1 |

  

6.ECOEL2021 scenario

6.1.ECOEL2021 scenario, model assumptions

This scenario assumes that Ecodesign measures are introduced in 2021 in a single tier and that the new Energy Labelling A-G scheme is also introduced in 2021.

The assumed effects of the introduction of the new labelling scheme on average LED-efficacy and average LED-prices are the same as described in Section 5.1 for the ELONLY scenario.

As regards the Ecodesign measures, the main difference between the ECOEL2021 and the BAU-scenario is that some classical lighting technologies are phased-out by the new proposed minimum efficacy requirements, and this leads to an accelerated shift of sales towards LED lighting products 
[33](#footnote33)
.

Some classical lamp types are already phased-out by existing regulations (244/2009, 245/2009, 1194/2012) and this effect is included in the BAU scenario. Consequently for the following light source types there is no difference between BAU and ECOEL2021:

-LFL T12 (phased-out from 2014)

-LFL T8 halo-phosphor (phased-out from 2014)

-HPM (High Pressure Mercury) (phased-out from 2015)

-HL MV X (DLS) (Directional mains-voltage halogen lamps) (phased-out from 2016)

-GLS R (DLS) (Incandescent non-halogen reflector lamps) (phased-out from 2016)

-HL MV E (NDLS) (Non-directional mains-voltage halogen lamps) (phased-out from 2018)

-GLS X (NDLS) (Non-directional incandescent non-halogen lamps) (phased-out 2009-2013)

For some other classical lamp types the new proposed efficacy requirements are identical to the existing requirements (even if there are some deviations due to the approximation by the new maximum power formula), or they are exempted both in the new proposal and in the existing regulations. Also in these cases, there is no difference between BAU and ECOEL2021:

-LFL T5 13-80W and T5 circular

-LFL X (all other LFL lamps, in the model including also T9 circular)

-HPS (High Pressure Sodium)

-MH (Metal Halide)

-CFLni (compact fluorescent without integrated control gear)

-HL R7s < 2700 lm 
[34](#footnote34)

For a third group of classical lamp types, proposed requirements are such that they will no longer be allowed on the market. For these lamps, a difference between the ECOEL2021- and the BAU-scenario appears from 2021, with some anticipatory effects from 2019 133:

-LFL T8t (tri-phosphor) with 2-, 4 or 5-feet length 
[35](#footnote35)

-CFLi (compact fluorescent with integrated control gear)

-HL LV C (Low-voltage halogen capsules with G4 or GY6.35 cap)

-HL MV C (Mains-voltage halogen capsules with G9 cap)

-HL R7s > 2700 lm 
[36](#footnote36)

-HL LV R (DLS) (MR11 - GU4 cap, MR16 - GU5.3 cap, AR111 - G53 cap) 
[37](#footnote37)

The above leads to the following shares of potential sales of non-LED lamps that are assumed to shift to LED lighting products (
[Table 45](#_Ref461009064)
).

Table 45: Percentage of the potential sales (replacements and new sales) for a non-LED base case technology that is assumed to shift to LED products (retrofit or light source in luminaire) in the BAU scenario and in the ECOEL2021 scenario for years 2015, 2020, 2025 and 2030.

|  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  | BAU scenario | | | |  | ECOEL2021 scenario | | | |
| Base Case | 2015 | 2020 | 2025 | 2030 |  | 2015 | 2020 | 2025 | 2030 |
| LFL T8 & T12128 | 5 | 20 | 40 | 60 |  | 5 | 34 | 94 | 96 |
| CFLi (NDLS) | 25 | 80 | 90 | 90 |  | 25 | 84 | 100 | |
| HL LV C (NDLS) | 10 | 50 | 70 | 90 |  | 10 | 60 | 99 | 100 |
| HL MV C (G9, NDLS) | 10 | 50 | 70 | 90 |  | 10 | 60 | 99 | 100 |
| HL MV L (R7s, NDLS) | 10 | 50 | 70 | 90 |  | 10 | 58 | 94 | 98 |
| HL LV R (DLS) | 15 | 30 | 50 | 70 |  | 15 | 44 | 100 | |
| LFL T5 | 0 | 10 | 40 | 60 |  | same as BAU | | | |
| LFL X | 0 | 10 | 40 | 60 |  | same as BAU | | | |
| HPS | 6 | 18 | 40 | 60 |  | same as BAU | | | |
| MH | 18 | 20 | 40 | 60 |  | same as BAU | | | |
| HPM | 42 | 99 | 100 | |  | same as BAU | | | |
| CFLni | 15 | 40 | 60 | 80 |  | same as BAU | | | |
| HL MV E (NDLS) | 15 | 90 | 100 | |  | same as BAU | | | |
| HL MV X (DLS) | 30 | 100 | | |  | same as BAU | | | |
| GLS R (DLS) | 50 | 100 | | |  | same as BAU | | | |
| GLS X (NDLS) | 30 | 100 | | |  | same as BAU | | | |

6.2.ECOEL2021 scenario, Sales

In the BAU-scenario the 2030 light source sales are 737 million units (
[Table 29](#_Ref462218707)
). In the ECOEL2021-scenario this drops to 650 million (-12%). The reason for this decrease is that in the ECOEL2021-scenario more classical lamp types with relatively low lifetime are replaced by LED products with higher lifetime. The latter need less frequent replacement (or none at all within the 2030 time-horizon) and thus replacement sales go down.

In 2030 almost all sales in the ECOEL2021-scenario regard LEDs; only some LFLs (T5), CFLni and HID-lamps remain. Note the peak in LED sales around 2020.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 46: ECOEL2021-scenario,  annual light source sales volumes in million units | | | | | | |
| EU-28 SALES | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 | |
| LFL | 269 | 390 | 285 | 209 | 66 | 37 | |
| CFL | 51 | 567 | 220 | 130 | 29 | 8 | |
| Tungsten-HL | 88 | 650 | 738 | 168 | 1 | 0 | |
| GLS | 1688 | 697 | 58 | 0 | 0 | 0 | |
| HID | 17 | 41 | 28 | 17 | 11 | 4 | |
| LED | 0 | 8 | 372 | 1213 | 759 | 601 | |
| GLS from Storage | 0 | 112 | 187 | 0 | 0 | 0 | |
| HL from Storage | 0 | 90 | 124 | 10 | 0 | 0 | |
| TOTAL (excl. from Storage) | 2112 | 2353 | 1702 | 1737 | 865 | 650 | |
| BAU for comparison | 2112 | 2353 | 1702 | 1737 | 929 | 737 | |
| Variation in ECOEL2021 |  |  |  |  | -64 | -87 | |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47019.jpg)

6.3.ECOEL2021 scenario, Stock

The total number of light sources installed in EU-28 is identical in the BAU- and ECO-scenarios. It increases with the years (more households, more light sources per household, increase in non-residential GDP), but in the same manner in all scenarios. This reflects the assumption in MELISA that Ecodesign and Labelling measures do not lead to changes in the installed number of light sources
[38](#footnote38)
.

However, the composition of the stock changes. In the BAU-scenario the 2030 stock for LEDs is 11.9 billion units (
[Table 30](#_Ref462225101)
). In the ECOEL2021-scenario this increases to 13.1 billion (+10%). The stock for non-LED light sources decreases correspondingly.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 47: ECOEL2021 scenario,  installed stock of light sources in million units | | | | | | |
| EU-28 STOCK | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 | |
| LFL | 1232 | 2008 | 2210 | 2222 | 1668 | 1002 | |
| CFL | 326 | 3684 | 4576 | 3569 | 1449 | 508 | |
| Tungsten-HL | 284 | 2043 | 2657 | 1190 | 58 | 0 | |
| GLS | 3694 | 1923 | 193 | 1 | 0 | 0 | |
| HID | 40 | 95 | 91 | 79 | 57 | 29 | |
| LED | 0 | 14 | 745 | 5265 | 10259 | 13096 | |
| GLS from Storage | 0 | 187 | 471 | 6 | 0 | 0 | |
| HL from Storage | 0 | 90 | 417 | 126 | 0 | 0 | |
| TOTAL (incl. from Storage) | 5576 | 10045 | 11360 | 12459 | 13492 | 14635 | |
| BAU for comparison | 5576 | 10045 | 11360 | 12459 | 13492 | 14635 | |
| Variation in ECOEL2021 |  |  |  |  | 0 | 0 | |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47020.jpg)

6.4.ECOEL2021 scenario, Electricity

[Table 48](#_Ref462226156)
 shows the EU-28 total electricity consumption for lighting in the ECOEL2021 scenario; the total consumption in the BAU-scenario is also shown for reference.

The savings (BAU – ECO) are 2 TWh/a (0.6%) in 2020, 26 TWh/a (8.4%) in 2025 and 41 TWh/a (14.0%) in 2030. A breakdown of these savings is presented in 
[Table 49](#_Ref462226193)
, which also indicates cumulative savings of 267 TWh (5.3%) over the period 2015-2030.

In 
[Table 49](#_Ref462226193)
 the electricity savings on classical technologies are separated from the additional electricity consumption (negative savings) by the LED products that replace them. For example, in 2030, the electricity consumption by LFL T8t is 59.9 TWh/a less than in the BAU-scenario, but these lamps have been replaced by LEDs that consume 26.9 TWh/a more than in the BAU-scenario, so the overall savings are 59.9-26.9 = 33.0 TWh/a.

By far the largest part of the electricity savings is due to the phase-out (and substitution by LED) of the LFL T8 tri-phosphor lamps in 2021. In 2030, 33 of the 41.9 TWh/a savings (79%) are due to LFL T8t. For the 2015-2030 cumulative savings this is 74%.

In comparison, savings on other classical lamp types are modest, even if not negligible: for some other (non-lighting) ecodesign products, savings of 1-4 TWh/a are considered important.

The 2021 phase-out of CFLi’s saves approximately 1.6 TWh/a in 2025 and 1.3 TWh/a in 2030 (net values, considering additional electricity by LEDs replacing them).

The 2021 phase-out of low-voltage halogen reflector lamps (HL LV R DLS) saves 3.7 TWh/a in 2025 and 1.7 TWh/a in 2030.

The 2020 phase-out of halogen capsules (HL LV C & HL MV C) saves approximately 0.9 TWh/a in 2025 while hardly any savings are obtained in 2030.

The partial phase-out in 2020 of linear halogen lamps with R7s cap (HL MV L) > 2700 lm leads to less than 0.2 TWh/a savings in 2025 while hardly any savings are obtained in 2030.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 48: ECOEL2021 scenario, EU-28 total Electricity consumption by light sources. Includes control gear energy. Excluded: controls, special purpose lamps, standby. | | | | | | |
| EU-28 ELECTRICITY | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 91 | 136 | 159 | 165 | 118 | 64 |
| CFL | 3 | 25 | 30 | 24 | 11 | 4 |
| Tungsten-HL | 8 | 46 | 52 | 22 | 1 | 0 |
| GLS | 90 | 46 | 4 | 0 | 0 | 0 |
| HID | 34 | 69 | 59 | 50 | 37 | 20 |
| LED | 0 | 0 | 15 | 54 | 119 | 169 |
| GLS from Storage | 0 | 4 | 10 | 0 | 0 | 0 |
| HL from Storage | 0 | 1 | 7 | 2 | 0 | 0 |
| TOTAL (incl. from Storage) | 225 | 328 | 336 | 318 | 286 | 257 |
| BAU for comparison | 225 | 328 | 336 | 320 | 312 | 299 |
| Savings in ECOEL2021 |  |  |  | 2.0 | 26.3 | 41.9 |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47021.jpg)

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Table 49 ECOEL2021 scenario, Savings on EU-28 Total Electricity Consumption for Lighting, in TWh/a or TWh cumulative) with respect to the BAU-scenario. Positive number indicates saving; negative number an additional electricity consumption. Includes electricity for light sources and control gears. Does not include electricity for control devices, special purpose lamps and during stand-by. | | | | |
|  | 2020 | 2025 | 2030 | cumulative  2015-2030 |
| Total EU-28, all sectors | 2.0 | 26.3 | 41.9 | 267 |
| total Residential (RES) | 0 | 4 | 3 | 31 |
| total Non-Residential (NRES) | 2 | 23 | 39 | 236 |
| total Classic Technology | 5 | 47 | 64 | 456 |
| total LED | -3 | -21 | -22 | -189 |
|  |  |  |  |  |
| LFL T8t | 3.7 | 39.9 | 59.9 | 400 |
| LFL T5 (13-80 W) | 0.0 | 0.0 | 0.0 | 0 |
| other LFL | 0.0 | 0.0 | 0.0 | 0 |
| LED in former LFL-applications | -2.5 | -21.4 | -26.9 | -204 |
| Total LFL-applications | 1.2 | 18.5 | 33.0 | 197 |
| HPM | 0.0 | 0.0 | 0.0 | 0 |
| HPS | 0.0 | 0.0 | 0.0 | 0 |
| MH | 0.0 | 0.0 | 0.0 | 0 |
| LED in former HID-applications | 0.0 | 1.3 | 3.8 | 18 |
| Total HID-applications | 0 | 1 | 4 | 18 |
| CFLni | 0.0 | 0.0 | 0.0 | 0 |
| LED in former CFLni-applications | 0.0 | 0.1 | 0.4 | 2 |
| Total CFLni-applications | 0 | 0 | 0 | 2 |
| HL LV R (MR/AR) (GU4,GU5.3,G53) | 0.6 | 4.5 | 1.8 | 32 |
| HL MV (DLS) (GU10 or E-cap) | 0.0 | 0.0 | 0.0 | 0 |
| GLS (DLS) | 0.0 | 0.0 | 0.0 | 0 |
| LED in DLS-applications | -0.1 | -0.8 | -0.1 | -6 |
| Total DLS-applications | 0.4 | 3.7 | 1.7 | 26 |
| CFLi | 0.2 | 1.6 | 2.0 | 15 |
| HL MV (NDLS, E-cap) | 0.0 | 0.0 | 0.0 | 0 |
| GLS (NDLS) | 0.0 | 0.0 | 0.0 | 0 |
| HL LV Capsule (G4, GY6.35) | 0.1 | 0.4 | 0.1 | 3 |
| HL MV Capsule (G9) | 0.2 | 0.5 | 0.0 | 4 |
| HL MV Linear (R7s) | 0.1 | 0.2 | 0.0 | 2 |
| LED in NDLS-applications | -0.2 | 0.0 | 0.8 | 1 |
| Total NDLS-applications | 0.4 | 2.7 | 3.0 | 24 |

6.5.ECOEL2021 scenario, GHG-emissions

The reduction in GHG-emissions in the ECOEL2021 scenario with respect to the BAU-scenario is 14.3 MtCO2eq/a in 2030 (-14%) or 94 MtCO2eq (-5%) cumulative over the period 2015-2030.

This reduction is a direct effect of the reduction in electricity consumption for light sources.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 50: BAU-Total EU-28 Greenhouse gas (GHG-) emission due to lighting electricity consumption in MtCO2eq/a or MtCO2eq cumulative, and reductions in the ECOEL2021 scenario | | | | | | |
| MtCO2eq |  | 2015 | 2020 | 2025 | 2030 | cumulative | |
| BAU | emission | 133 | 122 | 112 | 102 | 1878 | |
| ECOEL2021 | reduction |  | -0.7 | -9.5 | -14.3 | -94 | |

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47022.jpg)

  

6.6.ECOEL2021 scenario, User Expense for light sources

[Figure 15](#_Ref461024471)
 shows the EU-28 total Acquisition Cost, Electricity Cost and overall User Expense for light sources in the ECOEL2021-scenario; the corresponding values for the BAU-scenario are also indicated for comparison (blue line).

The Acquisition costs in the ECOEL2021 scenario are higher than in the BAU-scenario, with a maximum difference of +4.2 billion EUR/a around 2022/2023. This additional expense is due to the accelerated shift of sales towards LED products, and is the investment needed to obtain the electricity savings reported earlier.

The Electricity Costs in the ECOEL2021 scenario are lower than in the BAU-scenario, with a maximum decrease of -8.9 billion EUR/a in 2030. This decrease is due to the decrease of the electricity consumption.

As a consequence the total User Expense for light sources in the ECOEL2021 scenario is slightly higher than in the BAU-scenario for a short period around 2022. In later years the ECOEL2021 expense is lower than for BAU Expense.

A further breakdown of the User Expense Savings is presented in 
[Table 54](#_Ref461025728)
. In 2020 the additional expense (negative saving) in the ECOEL2021-scenario is -0.8 billion EUR/a, in 2025 the savings are 1.5 billion EUR/a and in 2030 7.7 billion EUR/a (9.3% of the BAU-Expense in that year). The cumulative savings over the period 2015-2030 are EUR 21 billion (1.8% of the BAU cumulative Expense).

In line with earlier findings, the major part of the monetary savings is obtained due to the 2021 phase-out of LFL T8t (6.0 of the EUR 7.7 billion per year in 2030).

  

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 51: ECOEL2021 scenario, EU-28 total Acquisition costs for light sources (acquisition and installation), in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. | | | | | | |
| EU-28  ACQUISITION COST | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 | |
| LFL | 3.84 | 5.53 | 4.01 | 2.95 | 0.92 | 0.52 | |
| CFL | 0.36 | 3.49 | 1.48 | 0.90 | 0.24 | 0.07 | |
| Tungsten-HL | 0.34 | 2.79 | 2.90 | 0.67 | 0.00 | 0.00 | |
| GLS | 2.08 | 0.86 | 0.07 | 0.00 | 0.00 | 0.00 | |
| HID | 0.52 | 1.44 | 1.02 | 0.62 | 0.38 | 0.15 | |
| LED | 0 | 0.29 | 8.05 | 12.09 | 12.65 | 11.22 | |
| GLS from Storage | 0 | 0.00 | 0.00 | 0.00 | 0.00 | 0.00 | |
| HL from Storage | 0 | 0.00 | 0.33 | 0.03 | 0.00 | 0.00 | |
| TOTAL ECOEL2021 | 7.15 | 14.40 | 17.86 | 17.25 | 14.20 | 11.96 | |
| BAU for comparison | 7.15 | 14.40 | 17.86 | 16.14 | 10.95 | 10.79 | |
| Additional due to ECOEL2021 |  |  |  | 1.1 | 3.3 | 1.2 | |

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 52: ECOEL2021 scenario, EU-28 total Electricity costs for light sources, in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. See  [Table 26](#_Ref427673918)  for applied electricity rates (from MEErP, incl. escalation 4%/a). | | | | | | |
| EU-28  ELECTRICITY COST | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 11.13 | 14.91 | 19.68 | 23.05 | 20.14 | 13.49 |
| CFL | 0.45 | 3.45 | 4.99 | 4.54 | 2.50 | 1.21 |
| Tungsten-HL | 1.17 | 6.93 | 9.57 | 4.43 | 0.26 | 0.00 |
| GLS | 14.91 | 7.21 | 0.78 | 0.00 | 0.00 | 0.00 |
| HID | 4.02 | 7.29 | 7.09 | 6.81 | 6.14 | 3.92 |
| LED | 0 | 0.03 | 2.01 | 8.62 | 22.12 | 37.50 |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.25 | 1.41 | 0.49 | 0.00 | 0.00 |
| TOTAL ECOEL2021 | 31.68 | 40.83 | 47.52 | 47.98 | 51.17 | 56.12 |
| BAU for comparison | 31.68 | 40.83 | 47.52 | 48.29 | 55.96 | 65.03 |
| Saving due to ECOEL2021 |  |  |  | 0.3 | 4.8 | 8.9 |

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 53: ECOEL2021 scenario, EU-28 total User Expense for light sources, in bn euros. Fixed EUR 2010, incl. 20% VAT for residential. In addition to Acquisition- and Electricity-costs from previous tables, this also includes maintenance costs for non-residential sector. | | | | | | |
| EU-28  TOTAL USER EXPENSE | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| LFL | 15.44 | 21.23 | 24.56 | 26.87 | 21.70 | 14.38 |
| CFL | 1.13 | 9.10 | 8.98 | 7.43 | 3.68 | 1.61 |
| Tungsten-HL | 1.64 | 10.34 | 13.19 | 5.51 | 0.29 | 0.00 |
| GLS | 17.68 | 8.43 | 0.88 | 0.00 | 0.00 | 0.00 |
| HID | 4.79 | 9.32 | 8.67 | 7.92 | 6.88 | 4.24 |
| LED | 0 | 0.32 | 10.34 | 22.56 | 39.16 | 55.03 |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |
| HL from Storage | 0 | 0.25 | 1.74 | 0.52 | 0.00 | 0.00 |
| TOTAL ECOEL2021 | 40.68 | 59.74 | 70.36 | 70.84 | 71.72 | 75.26 |
| BAU for comparison | 40.68 | 59.74 | 70.36 | 70.05 | 73.26 | 83.00 |
| Saving due to ECOEL2021 |  |  |  | -0.8 | +1.5 | +7.7 |

Additional Acquisition cost, maximum around 4200 mln euros/a higher in ECOEL2021

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47023.jpg)

8900 mln euros/a lower in ECOEL2021

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47024.jpg)

7700 mln euros/a lower in ECOEL2021

 

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47025.jpg)

Figure 15 ECOEL2021 scenario, EU-28 Total Acquisition Cost (top), Electricity Cost (centre) and Total User Expense (bottom) for light sources, in million euros, fixed EUR 2010 incl. residential VAT. BAU-totals shown for reference (blue line). Note: graphs have different scales.

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Table 54 ECOEL2021 scenario, Savings on EU-28 Total User Expense for Lighting, in billion euros, with respect to the BAU-scenario. Positive number indicates saving; negative number an additional expense. Fixed 2010 euros, includes VAT for residential. | | | | |
| ECOEL2021 cost savings vs. BAU | 2020 | 2025 | 2030 | cumulative  2015-2030 |
| Total EU-28, all sectors | -0.8 | 1.5 | 7.7 | 21.2 |
| total Residential (RES) | 0.0 | 0.5 | 0.9 | 3.9 |
| total Non-Residential (NRES) | -0.8 | 1.0 | 6.8 | 17.3 |
| total Classic Technology | 1.4 | 10.5 | 14.8 | 105.1 |
| total LED | -2.2 | -8.9 | -7.1 | -83.9 |
|  |  |  |  |  |
| LFL T8t | 0.9 | 8.1 | 13.3 | 85.2 |
| LFL T5 (13-80 W) | 0.0 | 0.0 | 0.0 | 0.0 |
| other LFL | 0.0 | 0.0 | 0.0 | 0.0 |
| LED in former LFL-applications | -1.7 | -7.3 | -7.3 | -70.7 |
| Total LFL-applications | -1 | 1 | 6 | 15 |
| HPM | 0.0 | 0.0 | 0.0 | 0.0 |
| HPS | 0.0 | 0.0 | 0.0 | 0.0 |
| MH | 0.0 | 0.0 | 0.0 | 0.0 |
| LED in former HID-applications | 0.0 | 0.0 | 0.5 | 1.2 |
| Total HID-applications | 0 | 0 | 1 | 1 |
| CFLni | 0.0 | 0.0 | 0.0 | 0.0 |
| LED in former CFLni-applications | 0.0 | 0.0 | 0.0 | -0.2 |
| Total CFLni-applications | 0 | 0 | 0 | 0 |
| HL LV R (MR/AR) (GU4,GU5.3,G53) | 0.2 | 1.4 | 0.6 | 10.3 |
| HL MV (DLS) (GU10 or E-cap) | 0.0 | 0.0 | 0.0 | 0.0 |
| GLS (DLS) | 0.0 | 0.0 | 0.0 | 0.0 |
| LED in DLS-applications | -0.2 | -0.6 | 0.0 | -4.6 |
| Total DLS-applications | 0 | 1 | 1 | 6 |
| CFLi | 0.2 | 0.7 | 0.8 | 7.0 |
| HL MV (NDLS, E-cap) | 0.0 | 0.0 | 0.0 | 0.0 |
| GLS (NDLS) | 0.0 | 0.0 | 0.0 | 0.0 |
| HL LV Capsule (G4, GY6.35) | 0.0 | 0.1 | 0.0 | 1.0 |
| HL MV Capsule (G9) | 0.1 | 0.2 | 0.0 | 1.2 |
| HL MV Linear (R7s) | 0.0 | 0.0 | 0.0 | 0.4 |
| LED in NDLS-applications | -0.3 | -0.9 | -0.4 | -9.6 |
| Total NDLS-applications | 0 | 0 | 0 | 0 |

7.ECOEL2TIERS scenario

The only difference with the ECOEL2021 scenario is that the phase-out of LFL T8 in the Ecodesign measures is postponed from 2021 to 2023. In the analysis model this translates into a different shift from LFL T8 to LEDs (see table below). Other light source types continue to be phased-out in 2021 (e.g. CFLi, halogens). Hence, the Ecodesign measures have two tiers, one in 2021 and one in 2023.

Introduction of the new Energy Labelling A-G scheme remains in 2021.

Table 55: Percentage of the potential sales (replacements and new sales) for LFL T8 that is assumed to shift to LED products in the BAU-, ECOEL2021 and ECOEL2TIERS scenarios

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
|  | LFL T8 => LED (%) | | | |
| Base Case | 2015 | 2020 | 2025 | 2030 |
| BAU | 5 | 20 | 40 | 60 |
| ECOEL2021 | 5 | 34 | 94 | 96 |
| ECOEL2TIERS | 5 | 20 | 94 | 100 |

Postponing the phase-out of LFL T8 from 2021 to 2023 decreases the electricity savings by 6.2 TWh/a in 2025 and 1.8 TWh/a in 2030. Cumulatively the decrease is 47 TWh over the period 2015-2030.

|  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Table 56: ECOEL2TIERS scenario, EU-28 total Electricity for light sources. | | | | | | | |
| EU-28 ELECTRICITY (TWh/a) | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 | |
| LFL | 91 | 136 | 159 | 169 | 134 | 72 |  | |
| CFL | 3 | 25 | 30 | 24 | 11 | 4 |  | |
| Tungsten-HL | 8 | 46 | 52 | 22 | 1 | 0 |  | |
| GLS | 90 | 46 | 4 | 0 | 0 | 0 |  | |
| HID | 34 | 69 | 59 | 50 | 37 | 20 |  | |
| LED | 0 | 0 | 15 | 52 | 108 | 163 |  | |
| GLS from Storage | 0 | 4 | 10 | 0 | 0 | 0 |  | |
| HL from Storage | 0 | 1 | 7 | 2 | 0 | 0 |  | |
| TOTAL ECOEL2TIERS | 225 | 328 | 336 | 319 | 292 | 259 | 4860 | |
| ECOEL2021 for comparison | 225 | 328 | 336 | 318 | 286 | 257 | 4812 | |
| Effect of postponement of LFL T8 phase-out from 2021 to 2023 |  |  |  | +1.2 | +6.2 | +1.8 | +47 | |

  

Postponing the phase-out of LFL T8 from 2021 to 2023 decreases the consumer expense savings by 1.2 billion EUR/a in 2025 and 0.9 billion EUR/a in 2030. Cumulatively the decrease is EUR 4.5 billion over the period 2015-2030.

|  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- |
| Table 57: ECOEL2TIERS scenario, EU-28 total Consumer Expense for light sources. | | | | | | | |
| EU-28 EXPENSE (bn EUR/a) | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 | |
| LFL | 15.44 | 21.23 | 24.56 | 27.79 | 24.53 | 15.97 |  | |
| CFL | 1.13 | 9.10 | 8.98 | 7.43 | 3.68 | 1.61 |  | |
| Tungsten-HL | 1.64 | 10.34 | 13.19 | 5.51 | 0.29 | 0.00 |  | |
| GLS | 17.68 | 8.43 | 0.88 | 0.00 | 0.00 | 0.00 |  | |
| HID | 4.79 | 9.32 | 8.67 | 7.92 | 6.88 | 4.24 |  | |
| LED | 0 | 0.32 | 10.34 | 20.82 | 37.53 | 54.36 |  | |
| GLS from Storage | 0 | 0.75 | 1.99 | 0.03 | 0.00 | 0.00 |  | |
| HL from Storage | 0 | 0.25 | 1.74 | 0.52 | 0.00 | 0.00 |  | |
| TOTAL ECOEL2TIERS | 40.68 | 59.74 | 70.36 | 70.01 | 72.92 | 76.18 | 1154 | |
| ECOEL2021 for comparison | 40.68 | 59.74 | 70.36 | 70.84 | 71.72 | 75.26 | 1150 | |
| Effect of postponement of LFL T8 phase-out from 2021 to 2023 |  |  |  | -0.8 | +1.2 | +0.9 | +4.5 | |

  

8.Scenario comparison, Summary and Conclusions

[Table 58](#_Ref462041446)
 summarizes the total EU-28 Electricity consumption, Greenhouse Gas emission and User Expense for lighting for the BAU-scenario, and the savings for the other scenarios. For additional insight see the graphs at the end of this summary.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 58: Total EU-28 Electricity Consumption for lighting in TWh/a or TWh cumulative, Total EU-28 GHG-emissions related to use of lighting in MtCO2eq/a or MtCO2eq cumulative, and Total EU-28 User Expense for lighting in bn EUR/a or bn EUR cumulative. Totals for the BAU-scenario and savings vs. BAU for the other scenarios. | | | | | | |
| Electricity (TWh)  [39](#footnote39) | | 2015 | 2020 | 2025 | 2030 | Cumul  [40](#footnote40) |
| BAU | Electricity | 336 | 320 | 312 | 299 | 5079 |
| ELONLY | saving |  | 0.0 | -4.2 | -11.5 | -54 |
| ECOEL2021 | saving |  | -2.0 | -26.3 | -41.9 | -267 |
| ECOEL2TIERS | saving |  | -0.8 | -20.1 | -40.1 | -220 |
| Emission (MtCO2eq) | | 2015 | 2020 | 2025 | 2030 | Cumulative |
| BAU | Emission | 133 | 122 | 112 | 102 | 1878 |
| ELONLY | saving |  | 0.0 | -1.5 | -3.9 | -19 |
| ECOEL2021 | saving |  | -0.7 | -9.5 | -14.3 | -94 |
| ECOEL2TIERS | saving |  | -0.3 | -7.2 | -13.6 | -77 |
| Expense (bn euros)  [41](#footnote41) | | 2015 | 2020 | 2025 | 2030 | Cumulative |
| BAU | Expense | 70 | 70 | 73 | 83 | 1171 |
| ELONLY | saving |  | 0.0 | 0.9 | -1.1 | 4 |
| ECOEL2021 | saving |  | 0.8 | -1.5 | -7.7 | -21 |
| ECOEL2TIERS | saving |  | 0.0 | -0.3 | -6.8 | -17 |

8.1.Electricity Consumption

In 2015 the EU-28 electricity consumption for lighting was 336 TWh/a, covering 12.2% of the overall EU-28 electricity use 
[42](#footnote42)
. The primary energy necessary to generate and distribute this electricity was 72 Mtoe, covering 4.4% of the EU-28 Gross Inland Consumption of energy 
[43](#footnote43)
.

In the BAU-scenario the electricity for lighting is expected to decrease to 299 TWh/a in 2030 (-12% vs. 2015), notwithstanding a 25% increase in the quantity of installed light sources. This decrease is due to the increased use of high-efficacy LED products.

Introduction of a new Energy Labelling A-G scheme in 2021 (ELONLY scenario) is projected to save 11.5 TWh/a (-3.8%) in 2030, and cumulatively 54 TWh until 2030.

Adding the Ecodesign measures with a single tier in 2021 (ECOEL2021 scenario), phasing-out CFLi, most halogen lamps and LFL T8 (2-, 4- and 5-feet), is projected to save 41.9 TWh/a (-14.0%) in 2030, and cumulatively 267 TWh until 2030.

Implementing the Ecodesign measures in 2 tiers, postponing the phase-out of LFL T8 to 2023, is projected to save 40.1 TWh/a (-13.4%) in 2030, and cumulatively 220 TWh until 2030.

Postponing the phase-out of LFL T8 from 2021 to 2023 decreases the electricity savings by 6.2 TWh/a in 2025 and 1.8 TWh/a in 2030. Cumulatively the decrease in savings is 47 TWh over the period 2015-2030.

The largest part of the ECOEL2021 electricity savings derives from the 2021 phase-out of LFL T8 tri-phosphor (79% of the 2030 savings; 74% of the cumulative savings) (
[Table 59](#_Ref462047073)
).

|  |  |  |  |  |
| --- | --- | --- | --- | --- |
| Table 59 Distribution over the various lamp types of the electricity savings in the ECOEL2021 scenario. 79% of the 2030 savings and 74% of the cumulative savings is due to the phase-out of LFL T8 in 2021. | | | | |
| ECOEL2021 scenario  electricity savings vs. BAU | 2020 | 2025 | 2030 | cumulative  2015-2030 |
| Total EU-28, all sectors | 2.0 | 26.3 | 41.9 | 267 |
|  |  |  |  |  |
| LFL-applications | 1.2 | 18.5 | 33.0 | 197 |
| HID-applications | 0.0 | 1.3 | 3.8 | 18 |
| CFLni-applications | 0.0 | 0.1 | 0.4 | 2 |
| DLS-applications | 0.4 | 3.7 | 1.7 | 26 |
| NDLS-applications | 0.4 | 2.7 | 3.0 | 24 |

8.2.Greenhouse Gas (GHG-) emissions

In 2015 the EU-28 GHG-emission due to use of light sources was 133 MtCO2eq/a, covering 2.8% of the overall EU-28 GHG-emission 
[44](#footnote44)
. In the BAU-scenario this is expected to reduce to 102 MtCO2eq/a in 2030 (-30% vs. 2015), due to decreased electricity use for lighting and due to reduced emissions per kWh during electricity generation and distribution.

Introduction of a new Energy Labelling A-G scheme in 2021 (ELONLY scenario) is projected to reduce GHG-emissions by 3.9 MtCO2eq/a (-3.8%) in 2030, and cumulatively by 19 MtCO2eq until 2030.

Adding the Ecodesign measures with a single tier in 2021 (ECOEL2021 scenario), phasing-out CFLi, most halogen lamps and LFL T8 (2-, 4- and 5-feet), is projected to reduce GHG-emissions by 14.3 MtCO2eq/a (-14.0%) in 2030, and cumulatively by 94 MtCO2eq until 2030.

Implementing the Ecodesign measures in 2 tiers, postponing the phase-out of LFL T8 to 2023, is projected to reduce emissions by 13.6 MtCO2eq/a (-13.3%) in 2030, and cumulatively by 77 MtCO2eq until 2030.

Postponing the phase-out of LFL T8 from 2021 to 2023 thus increases the GHG-emissions by 2.3 TWh/a in 2025 and by 0.7 TWh/a in 2030. Cumulatively the increase is 17 TWh over the period 2015-2030.

8.3.User Expense saving

The total EU-28 user expense for light sources (acquisition, installation, use, maintenance) in 2015 was 70 billion EUR/a
[45](#footnote45)
. In the BAU-scenario this is estimated to increase to 83 billion EUR/a by 2030, notwithstanding the decrease in electricity consumption. The increase is due to the assumed increase in electricity rate (euros/kWh, +4% per year, not counting inflation, MEErP prices, see Section 3.2 of this Annex).

Introduction of a new Energy Labelling A-G scheme in 2021 (ELONLY scenario) is projected to initially increase total user expenses for lighting by 0.9 billion EUR/a (+1.2%) in 2025. This additional expense is due to higher acquisition costs, i.e. an investment in LED light sources with higher energy efficiency, but also with higher unit prices. This investment gradually pays back in following years due to lower electricity costs, leading to 1.1 billion EUR/a lower user expenses (-1.3%) by 2030. Cumulatively over the period 2015-2030, the projection is an additional user expense of 4 billion euros. However, LED light sources bought in the period 2021-2030 will continue to provide monetary advantages also beyond 2030, leading to zero additional cumulative expenses around 2032 and EUR 8 billion cumulative expense savings by 2035.

Adding the Ecodesign measures with a single tier in 2021 (ECOEL2021 scenario), phasing-out CFLi, most halogen lamps and LFL T8 (2-, 4- and 5-feet), is projected to lead to 0.8 billion EUR/a additional expenses by 2020 (investment), to 1.5 billion EUR/a expense savings by 2025 and to 7.7 billion EUR/a savings by 2030. Cumulative savings over the period until 2030 are 21 billion euros.

Postponing the phase-out of LFL T8 from 2021 to 2023 increases the total user expenses in 2025 by 1.2 billion EUR/a and in 2030 by 0.9 billion EUR/a. Cumulatively over the period until 2030, total user expense is EUR 4 billion higher due to the postponement.

8.4.Graphs

For Electricity consumption, GHG-emission and User expense the following graphs are shown for the period 2015-2030:

-total annual values for the four scenarios;

-annual savings vs. BAU of the same year for the other three scenarios;

-Cumulative 2015-2030 savings vs. BAU for the other three scenarios.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47026.jpg)

Figure 16 Total EU-28 electricity consumption for lighting in TWh/a for BAU, ELONLY, ECOEL2021, and ECOEL2TIERS scenarios.

Effect of 2 year postponement of LFL T8 phase-out

ELONLY

ECOEL2021

ECOEL2TIERS

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47027.jpg)

Figure 17 Total EU-28 annual electricity savings in TWh/a for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU.

ECOEL2TIERS

ECOEL2021

ELONLY

Effect of 2 year postponement of LFL T8 phase-out

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47028.jpg)

Figure 18 Total EU-28 cumulative electricity savings in TWh for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47029.jpg)

Figure 19 Total EU-28 GHG-emission related to use of light sources in MtCO2eq/a for BAU, ELONLY, ECOEL2021, and ECOEL2TIERS scenarios.

ECOEL2TIERS

ECOEL2021

ELONLY

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47030.jpg)

Figure 20 Total EU-28 annual reduction in GHG-emission, in MtCO2eq/a, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU.

ELONLY

ECOEL2TIERS

ECOEL2021

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47031.jpg)

Figure 21 Total EU-28 cumulative reduction in GHG-emission, in MtCO2eq, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU.

BAU

ELOnly

ECOEL2tiers

ECOEL2021

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47032.jpg)

Figure 22 Total EU-28 acquisition cost for lighting in bn EUR/a for BAU, ELONLY, ECOEL2021, and ECOEL2TIERS scenarios.

ELOnly

ECOEL2021

ECOEL2tiers

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47033.jpg)

Figure 23 Total EU-28 annual additional acquisition cost, in bn EUR/a, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU

ELOnly

ECOEL2021

ECOEL2tiers

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47034.jpg)

Figure 24 Total EU-28 cumulative additional acquisition cost, in bn euros, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU

Figure 25 Total EU-28 electricity cost for lighting in bn EUR/a for BAU, ELONLY, ECOEL2021, and ECOEL2TIERS scenarios.

ECOEL2tiers

ECOEL2021

ELOnly

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47035.jpg)

Figure 26 Total EU-28 annual energy cost saving, in bn EUR/a, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU

ELOnly

ECOEL2tiers

ECOEL2021

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47036.jpg)

Figure 27 Total EU-28 cumulative energy cost saving, in bn EUR/a, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU

BAU

Return on Investment: lower electricity cost

Additional Investments in LED

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47037.jpg)

Figure 28 Total EU-28 user expense for lighting in bn EUR/a for BAU, ELONLY, ECOEL2021, and ECOEL2TIERS scenarios.

Return on Investment: lower electricity cost

Additional Investments in LED

ELONLY

ECOEL2TIERS

ECOEL2021

 

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47038.jpg)

Figure 29 Total EU-28 annual user expense saving, in bn EUR/a, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU (negative value is additional expense)

ECOEL2TIERS

ECOEL2021

ELONLY

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47039.jpg)

ELONLY

ECOEL2TIERS

ECOEL2021

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47040.jpg)

Figure 30 Total EU-28 cumulative user expense saving, in bn EUR, for ELONLY, ECOEL2021, and ECOEL2TIERS scenarios with respect to BAU (negative value is additional expense).

Top: period 2015-2030; bottom: period 2015-2040.

  

9.Sensitivity analysis for electricity rates

The monetary results presented in the preceding sections are based on the MEErP electricity rates (EUR/kWh) presented in Section 3.2 of this Annex. These rates follow Eurostat data until 2016 and then apply a 4%/a escalation rate, as suggested in the MEErP.

In the PRIMES model of the Commission, a different projection for electricity rates is used, with a much lower price escalation. The PRIMES model has separate rates for the tertiary sector (higher) and for industry (lower). For application in MELISA, a single electricity rate for non-residential has been defined assuming 80% tertiary sector and 20% industry sector. This leads to a non-residential electricity rate that is higher than the ‘MEErP’ rate (that is based on industry-only), also in earlier years. The electricity prices derived from PRIMES have been presented in Section 3.2 of this Annex.

Graphs below compare the electricity rates from MEErP and PRIMES.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47041.jpg)

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_47042.jpg)

 

Figure 31 Comparison of electricity rates according to MEErP (Eurostat until 2016, then 4%/a escalation) and according to PRIMES model (EU-28 Reference scenario REF2015f; uses 80% tertiary, 20% industry).

Table 60 Difference in monetary results between using MEErP or PRIMES electricity rates in MELISA. Costs in bn EUR for EU-28 all sectors. Fixed EUR 2010, incl. VAT for residential. Total expenses also include maintenance costs, which are not shown separately. Positive savings indicate additional costs. (see remarks following the table)

|  |  |  |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost | 17.86 | 16.14 | 10.95 | 10.79 | 221.90 |  | Acquisition cost | 17.86 | 16.14 | 10.95 | 10.79 | 221.90 |
| Electricity cost | 47.52 | 48.29 | 55.96 | 65.03 | 852.90 |  | Electricity cost | 52.22 | 52.26 | 51.92 | 50.45 | 830.90 |
| Total expense | 70.36 | 70.05 | 73.26 | 83.00 | 1170.90 |  | Total expense | 75.06 | 74.02 | 69.21 | 68.42 | 1148.90 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |
| ELONLY | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | ELONLY | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost | 17.86 | 16.14 | 12.61 | 12.28 | 236.90 |  | Acquisition cost | 17.86 | 16.14 | 12.61 | 12.28 | 236.90 |
| Electricity cost | 47.52 | 48.29 | 55.17 | 62.46 | 841.80 |  | Electricity cost | 52.22 | 52.26 | 51.21 | 48.49 | 821.80 |
| Total expense | 70.36 | 70.05 | 74.12 | 81.92 | 1174.90 |  | Total expense | 75.06 | 74.01 | 70.16 | 67.95 | 1154.80 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |
| ELONLY vs. BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | ELONLY vs. BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost saving | 0 | 0 | 1.66 | 1.49 | 15.00 |  | Acquisition cost saving | 0 | 0 | 1.66 | 1.49 | 15.00 |
| Electricity cost saving | 0 | 0 | -0.79 | -2.56 | -11.10 |  | Electricity cost saving | 0 | 0 | -0.71 | -1.96 | -9.10 |
| Total expense saving | 0 | 0 | 0.87 | -1.08 | 4.00 |  | Total expense saving | 0 | 0 | 0.95 | -0.48 | 5.90 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |
| ECOEL2021 | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | ECOEL2021 | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost | 17.86 | 17.25 | 14.20 | 11.96 | 252.00 |  | Acquisition cost | 17.86 | 17.25 | 14.20 | 11.96 | 252.00 |
| Electricity cost | 47.52 | 47.98 | 51.17 | 56.12 | 801.60 |  | Electricity cost | 52.22 | 51.93 | 47.52 | 43.45 | 786.40 |
| Total expense | 70.36 | 70.84 | 71.72 | 75.26 | 1149.70 |  | Total expense | 75.06 | 74.79 | 68.07 | 62.59 | 1134.50 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |
| ECOEL2021 vs. BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | ECOEL2021 vs. BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost saving | 0 | 1 | 3.25 | 1.17 | 30.10 |  | Acquisition cost saving | 0 | 1 | 3.25 | 1.17 | 30.10 |
| Electricity cost saving | 0 | 0 | -4.79 | -8.91 | -51.30 |  | Electricity cost saving | 0 | 0 | -4.40 | -7.01 | -44.50 |
| Total expense saving | 0 | 1 | -1.53 | -7.73 | -21.20 |  | Total expense saving | 0 | 1 | -1.14 | -5.84 | -14.40 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |
| ECOEL2TIERS | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | ECOEL2TIERS | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost | 17.86 | 16.26 | 14.36 | 12.51 | 248.70 |  | Acquisition cost | 17.86 | 16.26 | 14.36 | 12.51 | 248.70 |
| Electricity cost | 47.52 | 48.14 | 52.21 | 56.49 | 809.40 |  | Electricity cost | 52.22 | 52.12 | 48.52 | 43.74 | 794.00 |
| Total expense | 70.36 | 70.01 | 72.92 | 76.18 | 1154.20 |  | Total expense | 75.06 | 73.99 | 69.23 | 63.43 | 1138.70 |
|  |  |  |  |  |  |  |  |  |  |  |  |  |
| ECOEL2TIERS vs. BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |  | ECOEL2TIERS vs. BAU | 2015 | 2020 | 2025 | 2030 | Cumulative 2015-2030 |
| MEErP rates |  |  |  |  |  |  | PRIMES rates |  |  |  |  |  |
| Acquisition cost saving | 0 | 0 | 3.42 | 1.72 | 26.80 |  | Acquisition cost saving | 0 | 0 | 3.42 | 1.72 | 26.80 |
| Electricity cost saving | 0 | 0 | -3.75 | -8.54 | -43.50 |  | Electricity cost saving | 0 | 0 | -3.39 | -6.71 | -36.90 |
| Total expense saving | 0 | 0 | -0.34 | -6.82 | -16.70 |  | Total expense saving | 0 | 0 | 0.02 | -4.99 | -10.20 |

Acquisition costs do not change when considering different electricity rates, so the columns for MEErP rates and for PRIMES rates display the same acquisition costs and associated savings (additional costs).

The electricity costs using PRIMES rates are generally higher in earlier years (2015, 2020) and lower in later years (2025, 2030). In earlier years this is due to the non-residential rate being higher for PRIMES. In later years this is due to the much smaller price escalation in PRIMES, both for residential and for non-residential rates. See the graphs at the start of this section for reference.

For all scenarios, the total expense savings with respect to the BAU-scenario are smaller when using PRIMES electricity rates, but the differences do not change overall trends. The classification of the scenario options according to their monetary savings does not change when using PRIMES electricity rates instead of MEErP electricity rates.

:   [(1)](#footnoteref1)
     Ref. Ares(2018)3220771 - 18/06/2018
:   [(2)](#footnoteref2)

     
    [Omnibus Review Study on Cold Appliances, Washing Machines, Dishwashers, Washer-Driers, Lighting, Set-top Boxes and Pumps – VHK, VITO, Viegand Maagøe and Wuppertal institute, March 2014.](https://www.vhk.nl/downloads/Reports/2014/VHK%20497%20Omnibus%20Study%20-%20Final%20Report%20-%2012-03-2014.pdf)
     (Omnibus Review Study 2014)
:   [(3)](#footnoteref3)

     
       Preparatory Study on Light Sources for Ecodesign and/or Energy Labelling Requirements (‘Lot 8/9/19’), Final Report, Tasks 1-7, VHK for the European Commission, October 2015. 
    <http://ecodesign-lightsources.eu/documents>
:   [(4)](#footnoteref4)

     
    <https://www.vhk.nl/>
:   [(5)](#footnoteref5)

     
       Market Overview on Directional Mains-Voltage Lamps related to stage 3 of Commission Regulation (EU) No 1194/2012, VHK for the European Commission, 3 September 2015, 
    <https://ec.europa.eu/energy/sites/ener/files/documents/Draft%20Final%20Market%20Assessment%20data.pdf>
:   [(6)](#footnoteref6)

     
       Communication from the Commission, Market assessment on mains-voltage lamps as required by Commission Regulation (EU) No 1194/2012, COM(2015) 443 final, 11.9.2015
:   [(7)](#footnoteref7)

     
       Commission Delegated Regulation (EU) No 518/2014 of 5 March 2014 amending Commission Delegated Regulations (EU) No 1059/2010, (EU) No 1060/2010, (EU) No 1061/2010, (EU) No 1062/2010, (EU) No 626/2011, (EU) No 392/2012, (EU) No 874/2012, (EU) No 665/2013, (EU) No 811/2013 and (EU) No 812/2013 with regard to labelling of energy-related products on the internet, OJ L 147, 17.5.2014, p.1
:   [(8)](#footnoteref8)

     
       Commission Regulation (EU) 2015/1428 of 25 August 2015 amending Commission Regulation (EC) No 244/2009 with regard to ecodesign requirements for non-directional household lamps and Commission Regulation (EC) No 245/2009 with regard to ecodesign requirements for fluorescent lamps without integrated ballast, for high intensity discharge lamps, and for ballasts and luminaires able to operate such lamps and repealing Directive 2000/55/EC of the European Parliament and of the Council and Commission Regulation (EU) No 1194/2012 with regard to ecodesign requirements for directional lamps, light emitting diode lamps and related equipment, OJ L 224, 27.8.2015, p.1
:   [(9)](#footnoteref9)

     
    [Kemna, R.B.J., Methodology for the Ecodesign of Energy-related Products (MEErP) – Part 2, VHK for the European Commission, 2011](https://www.vhk.nl/downloads/Reports/2011/VHK%20473%20MEErP.ZIP)
    . (MEErP)
:   [(10)](#footnoteref10)
     
    <https://ec.europa.eu/info/consultations/public-consultation-ecodesign-and-energy-labelling-refrigerators-dishwashers-washing-machines-televisions-computers-and-lamps_en>
:   [(11)](#footnoteref11)
     
       Scale ranging from not important, somewhat important, important, very important, don’t know or no opinion and no answer.
:   [(12)](#footnoteref12)
     For products placed on the market before the date of application of the new label and that will be on the shelves of dealers with the old label after 1 June 2022, suppliers would need to provide dealers with a sticker with the new label on the request of dealers until 1 June 2022.
:   [(13)](#footnoteref13)

     
       Data from the MELISA model, October 2017 update.
:   [(14)](#footnoteref14)

    http://ecodesign-lightsources.eu/documents
:   [(15)](#footnoteref15)

    <http://ecodesign-lightsources.eu/sites/ecodesign-lightsources.eu/files/attachments/LightSources%20Task7%20Final%2020151031.pdf>
    , Annexes D, E and F.
:   [(16)](#footnoteref16)

     
       See the Task 2 and Task 3 reports of the Lot 8/9/19 preparatory study on Light Sources.
:   [(17)](#footnoteref17)

     
       These changes mainly regard the lifetime (longer), average luminous flux, power and efficacy of LFL and HID-lamps. The lifetime for LEDs substituting LFL and HID was also increased. To enable lifetime to be variable with the years, a lifetime distribution was introduced for LFL T8t, LFL T5, HPS, MH and LEDs substituting these lamps. The main effect of these changes, with respect to results reported in Task 7 of the Light Sources study, was that energy savings in 2020 and 2025 slightly decreased while savings in 2030 increased.
:   [(18)](#footnoteref18)

    ‘Accelerating the Global Adoption of Energy-Efficient Lighting’, UN Environment – Global Environment Facility | United for Efficiency (U4E), U4E policy guide series, UNEP 2017, in particular figure 4 (based on US DoE 2016 data).
:   [(19)](#footnoteref19)

     
       http://ecodesign-lightingsystems.eu/documents
:   [(20)](#footnoteref20)

    Separate rates are used for residential and non-residential applications. Until 2016 the rates are based on Eurostat. For following years an escalation rate of 4% per year is applied according to the MEErP. An alternate approach using electricity rates from the PRIMES model has been used for sensitivity analysis.
:   [(21)](#footnoteref21)
     MELISA is a light sources model and does not consider luminaire data. All data for ‘integrated LED luminaires’ actually refer to the light sources (LED modules, LED light engines) inside those luminaires.
:   [(22)](#footnoteref22)

    This factor reflects the tendency for users to buy LEDs with slightly higher flux than the classical lamps they replace, and the tendency to increase the annual operating hours, knowing that LEDs consume less energy. The rebound factor for flux varies from 1.025 to 1.1; the factor for hours from 1.0 to 1.025.
:   [(23)](#footnoteref23)

    These aspects are being considered in the parallel ENER Lot 37 Lighting Systems study.
:   [(24)](#footnoteref24)
     For residential the prices up to 2016 are based on Eurostat, extraction 27 October 2017, Households Band DC 2500<consumption<5000 kWh, all taxes and levies included. For non-residential the reference for prices up to 2016 was Eurostat, extraction 18 July 2017, Industrial users Band IC: 500 MWh < Consumption < 2000 MWh, excluding VAT and other recoverable taxes and levies.
:   [(25)](#footnoteref25)
     EU-28 Reference scenario (REF2015f)
:   [(26)](#footnoteref26)
     Mega-tonnes carbon dioxide equivalent global warming potential; Mt = 1 billion kilos. For comparison, the total EU-28 GHG emission is 4721 MtCO2eq/a (source: EEA, GHG Inventory 2012. Total for EU-28 excl. land use, land-use change and forestry (LULUCF).)
:   [(27)](#footnoteref27)
     These values have been taken from MEErP Part 1 table 30 and Part 2 page 125-126, http://ec.europa.eu/growth/industry/sustainability/ecodesign\_en (section on ‘support tools for experts’). MEErP in turn uses latest PRIMES model projections that were available in 2011 for the carbon intensity of EU strict electricity generation, increased with (a small number of around 0.028kg/kWh) CO2 emissions for extraction, preparation and transport of fuels as well as distribution losses minus a credit for for derived heat
:   [(28)](#footnoteref28)
     In the model, potential sales of LFL T12 and LFL T8h first shift to potential sales of LFL T8t. The share that becomes LED is applied to these latter potential sales.
:   [(29)](#footnoteref29)
     All electricity values include control gear energy but exclude control devices, special purpose lamps and stand-by. The primary energy consumption is approximately 2.5 times the reported amount of electricity.
:   [(30)](#footnoteref30)
     According to the Eurostat Energy Balance Sheet 2014, the total EU-28 electricity consumption in 2014 was 232.7 Mtoe = 2706 TWh, http://ec.europa.eu/eurostat/documents/3217494/7571929/KS-EN-16-001-EN-N.pdf/28165740-1051-49ea-83a3-a2a51c7ad304
:   [(31)](#footnoteref31)
     Assuming an average EU-28 efficiency of electricity generation and distribution of 40%, and conversion factors 1 Mtoe = 11.63 TWh = 41.87 PJ: 335\*2.5 = 837 TWh /11.63 = 72 Mtoe \* 41.87 = 3014 PJ. According to the Eurostat Energy Balance Sheet 2014 the Gross Inland Consumption of Energy was 1606 Mtoe in 2014.
:   [(32)](#footnoteref32)
     The total EU-28 GHG emission is 4721 MtCO2eq/a (source: EEA, GHG Inventory 2012. Total for EU-28 excl. land use, land-use change and forestry (LULUCF).)
:   [(33)](#footnoteref33)
     In the model, such a phase-out and associated accelerated shift to LED is gradual. As a general guide, the following is applied when a lamp type is phased-out in a year X:Year X-2: % sales remaining classical technology is 90% of the BAU-valueYear X-1: % sales remaining classical technology is 80% of the BAU-valueYear X : % sales remaining classical technology is 50% of the BAU-valueYear X+1: % sales remaining classical technology is 20% of the BAU-valueYear X+2: % sales remaining classical technology is 10% of the BAU-valueYear X+3: % sales remaining classical technology is 5% of the BAU-valueLater: % sales remaining classical technology is 0% (all sales shift to LED)
:   [(34)](#footnoteref34)
     For the residential sector it is assumed that this regards 80% of all HL R7s models; for the non-residential sector 20%.
:   [(35)](#footnoteref35)
     The analysis assumes that this regards 90% of LFL T8 models
:   [(36)](#footnoteref36)
     For the residential sector it is assumed that this regards 20% of all HL R7s models; for the non-residential sector 80%.
:   [(37)](#footnoteref37)
     A small part with beam angle ≤10˚ is exempted from the proposal and might continue to exist, but this has a non-quantifiable (but anyway small) impact and is neglected in the analyses.
:   [(38)](#footnoteref38)
     The average luminous flux and/or the average annual operating hours are assumed to change slightly when passing to LED, but this is implemented by a rebound factor on these parameters; it does not change the quantity of installed light sources.
:   [(39)](#footnoteref39)
     Electricity consumption includes control gears, but excludes controls, special purpose, stand-by
:   [(40)](#footnoteref40)
     Cumulative over period 2015-2030
:   [(41)](#footnoteref41)
     User Expense includes purchase, installation, operation and maintenance of light sources and control gears. Additional luminaire costs are not included. Expense is in fixed 2010 euros, incl. VAT for residential. Negative numbers are a saving; positive numbers indicate an additional expense.
:   [(42)](#footnoteref42)
     According to the Eurostat Energy Balance Sheet, 2017 edition with 2015 data, the total EU-28 electricity consumption in 2015 was 235.9 Mtoe = 2743 TWh
:   [(43)](#footnoteref43)
     Assuming an average EU-28 efficiency of electricity generation and distribution of 40%, and conversion factors 1 Mtoe = 11.63 TWh = 41.87 PJ: 336\*2.5 = 840 TWh /11.63 = 72 Mtoe \* 41.87 = 3024 PJ. According to the Eurostat Energy Balance Sheet, 2017 edition with 2015 data, the Gross Inland Consumption of Energy was 1626 Mtoe in 2015.
:   [(44)](#footnoteref44)
     MtCO2eq= Mega-tonnes carbon dioxide equivalent global warming potential; Mt = 1 billion kilos. For comparison, the total EU-28 GHG emission is 4721 Mt CO2 eq/a (source: EEA, GHG Inventory 2012. Total for EU-28 excl. land use, land-use change and forestry (LULUCF).)
:   [(45)](#footnoteref45)
     This does not include additional costs for the acquisition, installation and maintenance of luminaires: only the light sources and control gears inside these luminaires and the costs for their electricity consumption are included.

[Top](#document2)

Annex 5: Minutes of the Ecodesign Consultation Forum

Brussels, 7 December 2017

Welcome and Introduction

The Chair welcomed the participants and explained the purpose of the meeting i.e. to discuss the results of the review study regarding Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2009 for ecodesign and Regulation (EU) No 874/2012 for energy labelling and the proposed draft working documents.

1.Adoption of the agenda and approval of the minutes of previous meetings 

The agenda was adopted without any changes.

2.State of play concerning the Combined Ecodesign and Energy labelling Consultation Forum 

The chair explained that in accordance with the new energy labelling framework regulation, a consultation forum for energy labelling needs to be set up, to be combined with that for ecodesign. The aim is to launch the call for interest for this combined consultation forum in the first quarter of 2019. Existing members of the consultation forum (except for the Member States) need to reapply for membership.

3.Presentation of the main findings of the review study

After a presentation by the Contractor (Van Holsteijn en Kemna) of the review study, the ensuing discussion raised the following points:

Timing for the phase out of all non-LED products – SE asked for clarification on the fact that the study did not look into the possibility to have a phase out of all non-LED lamps in 2024. The Contractor stated that the idea to have all conventional lamps phased out in 2024 was one of the controversial points at the previous Ecodesign Consultation Forum of 2015 and that it was removed from the study to reach compromise.

Incandescent special purposes lamps – PL suggested that the EU could focus on the missed savings from incandescent lamps instead of proposing a phase out of T8 fluorescent lamps. Seeing that incandescent lamps are not part of the study, PL stated that although these lamps were banned years ago, they are still a relevant part of the market in the EU because the legislation exempts incandescent lamps for special purposes, also for general use. AT added that this situation is true also for other phased out lamps. The Contractor stated that incandescent technologies (except halogens) are not considered anymore in the study.

The Commission Services stated that incandescent lamps should not be on the market any longer, except for minor quantities for special purposes as laid down in the EU legislation and that it is the role of national market surveillance authorities to look at what is placed on the market. On their side, the Commission Services are proposing in the draft texts to tighten the conditions for exemptions, to avoid such loopholes in the future. It would be interesting to have some statistics on the number of lamps on the market.

4.Presentation of the working documents

After a presentation by the Commission Services of the working documents the ensuing discussion raised the following points:

4.1.Ecodesign

Article 1 – Scope and Annex I - Exemptions

Placing on the market and Putting into service – CLASP underlined that the concept of "placing on the market" does not imply that users are obliged to replace lamps and systems on the day of application, but that from that day the phased out products would not be allowed to enter the EU market anymore. Lamps in use and in stock can be used with no end date. UK pointed to the fact that the regulation would need to include at some point in the scope the "putting into service" of lighting products in addition to "placing on the market", as lighting may well be provided as a service.

Exemptions – IT asked to exempt lamps used in laboratories, which are normally halogens, and to make it more clear which lamps would be exempted following the requirement for max. 1000 lumen per mm² of projected light-emitting surface area (which are listed in the explanatory memorandum). LightingEurope stated that they would like to keep many of the current exemptions for special purpose lamps and they will share two drafting options: a list or, preferably, a definition for special purpose lamps that would close the current loopholes especially for the misuse of incandescent lamps. LightingEurope also asked to add as an exemption ‘works of art’ as defined in Directive 2001/84/EU, because these works are handcrafted in small quantities. PL and DE opposed keeping the exemption for lamps for ambient temperatures below -30º and above 120º, which creates a major loophole for incandescent lamps as any incandescent lamp can satisfy those values. They proposed to add either a max. voltage of e.g. 25V or restrict the exemption based on the length of the lamp. ECOS supported this point and was satisfied with the attempt to close the loophole for decorative lamps. IALD asked to keep exemptions for theatre lighting, photosensitive people and photosensitive artworks. DE supported the exemption for theatre lighting and stated that exemptions should be a clear cut and easily checkable by market surveillance authorities. DE therefore asked to delete the option to allow "other documentation" to exempt products that were "specifically tested and approved" to operate in the contexts listed in Annex I. CECED asked to exempt lamps in range hoods because these lamps are already regulated in a separate regulation. CER asked to exempt all lamps that are used on trains, including common T8 lamps, as stockpiling would not help because these lamps are replaced every 3-4 years (according to the Contractor: every 15 years). EIM added that they would be obliged to retrofit stations and platforms on September 2020. The Commission Services clarified that today's interpretation is that common lights not specifically designed and tested for trains are not exempt and asked CER to give data on how many lights would be affected, taking into account the general exemption for means of transport from the ecodesign framework regulation and the specific exemption in Annex I(f) for railway vehicle lighting. The Commission Services clarified to EIM that on September 2020 there would not be new T8 placed on the market, but no station would be obliged to replace them.

Containing products – AT stated that it is unclear what a containing product is, supported by IT, which also feared that manufacturers/importers of containing products may ignore that they are subject to a requirement that covers a product within their products. SE considered that when the lighting products in scope of the regulation are contained in a product, they should satisfy the ecodesign requirements and supported the proposal that the manufacturer of a containing product should give the information on the type of light source used and its energy class. DK stated that they feel relatively confident that they can work with having containing products in scope. IALD is very concerned about the burden that would be imposed on the producers of containing products. LightingEurope stated that, with light sources and control gears in scope, the definition of the scope should make it clear that containing products are not in scope. Independent Retail Europe stated that a containing product which is already subject to an energy label, like fridges, should not be required to have a second energy label for the lighting product that it contains. The Commission clarified that this will not be the case: the requirement is to inform on the type of light and energy class of the light source contained in the product. CECED was happy with this clarification but asked: 1. to exempt containing products which are already covered by energy labelling; 2. to anyway clarify if the date of placement on the market of a lamp in a containing product would be that of the lamp itself or of the containing product; and 3. to exempt lamps which are today used in fridges and similar products, in order to keep replacements available (and avoid to throw away the fridge when the lamp breaks, in line with the "repair as produced principle"). The Commission Services asked CECED for evidence and more information on this last point and replied that if the lamp was placed on the market before it is integrated in a containing product, the lamp date stays valid. The Commission Services asked for drafting contributions on this point, stating that it is important to agree on the principle.

Article 2 – Definitions and Annex II – Definitions

Merging article 2 and Annex II – SE asked to merge them.

White light definition (chromaticity coordinates x,y) – SE and DK showed concern about the narrowing of the white light area that would leave many common products out of scope. In support of this point, BE added that having special purpose lamps naturally falling out of the scope, would be a step back for consumers protection, as these lamps will not be subject any longer to information requirements. CLASP (supported by SE) asked to re-expand the white light area something mid-way and also asked the Commission to consider replacing the x,y space, with the method "u prime, v prime", which is easier to understand and visualise. UK would like to know more about the calculations to expand the white light area. CLASP will share slides with all participants and the Commission will check the “u prime, v prime” method. The Contractor and the Commission clarified that the white area is the same than the one already used in two of the three current regulations. The currently bigger white area in the third regulation has required laying down exemptions for many special purpose lamps, whose verification has been time and resource consuming for market surveillance authorities. With the proposed definition of white area, fewer exemptions would be needed and the administrative burden would be reduced. There is no requirement for products out of scope to prove that they are out of scope. LightingEurope welcomed the alignment of the white light area to two of the three current regulations and stated that they would not see risk of loopholes from this. The Commission will better investigate how many products would naturally fall out of scope.

Containing product which is itself a light source (see also the discussion on article 4) – AT asked to clarify if fully integrated luminaires are in scope or not: the confusion would come from the last sentence of definition (1) "light source", which proposes to consider as the light source in scope "the smallest physical unit that can be readily removed from the containing product". The Commission reminded that the aim of that sentence, together with the provisions on removability in article 4 supporting a circular economy, is to avoid sealed luminaires. IT commented that it is impossible to avoid sealed luminaires (e.g. lights for underwater use) and added that "the smallest physical unit" is confusing (for example, in a LED module, would it be the single LED?). Also in the case of a fridge, what would be the containing product: the fridge or the grid that contains that LED? CLASP noted that lights for marine applications are exempt. DE stated that without a clear definition for the "smallest physical unit", there could be loopholes. NL proposed to delete the last sentence of definition (1) "light source", as it is already clear that a fully integrated luminaire is assimilated to a light source and thus it is in scope. DK supported the deletion of the sentence but stressed the need to identify a light source for verification purposes: an option is that if it is not possible to remove the lighting product from a containing product, the whole containing product may be tested as a lighting product. SE supported the Commission's proposal to have all lights removable. SE added that the ambition in any case should not be lower than having a fully integrated luminaire tested as a light source.

Luminous flux < 1000 lumen per mm² of projected light-emitting surface area – IT stated that this definition is useless and badly written, and would send suggestions to improve the definition.

Luminous flux – SE proposed to lower the minimum level of luminous flux from 60 lumen to 30 lumen, in order to have in scope "cosy" lamps with soft light that are popular in Scandinavia for general lighting needs. DE supported this point.

Useful luminous flux/Total luminous flux – CLASP proposed to drop the definition of "useful" luminous flux for directional lamps and use instead the "total" luminous flux, as in a normal environment all forward lumens from a directional lamp are useful and not only those in a cone. Using the total flux would allow market surveillance authorities to use integrating spheres instead of goniophotometers for measuring these light sources, which would lower costs, lead to more market surveillance and simplify the calculation formula proposed in the draft legislation by removing the correction factors. SE supported CLASP and confirmed that it is much easier to measure the total flux than the useful flux. IALD replied in favour of calculating the useful luminous flux, saying that what counts for the designer is the directionality of lights in order to have the right light at the right place.

Separate control gear – DE asked to clarify the wording for a separate control gear that is part of a containing product.

Fluorescence or fluorescent light source – IT would send suggestions to improve this definition.

Extra low voltage – CECAPI asked to refer to alternate current too and not only to direct current.

Stand-by – NL would send suggestions to align this definition to the standby legislation.

Portable battery-operated product – CECED asked to explain the limitation to 24 V.

Definitions in the energy labelling act – IT asked to check that the same definitions are worded the same in the ecodesign and the energy labelling acts.

Article 3 – Ecodesign requirements

See comments to Annex III.

Article 4 – Removal of light sources and separate control gears

CLASP stated that it is an excellent proposal to have luminaires serviceable and brought the experience of the industry voluntary initiative Zhaga, which published standards on the serviceability of products. IALD underlined that we are not in a world of light bulbs anymore, rather in a world of electronic components. As the efficiency of an electronic component is determined by its thermal coupling, making a product dismountable affects its efficiency. IALD suggested limiting the discussion to replaceable control gear, because a chip control gear makes a product fail early. AT stated that removability of light sources is a highly important issue, in particular for domestic luminaires where there are many cheap products, and proposed to consider a warranty on the lifetime of office products and systems rather than imposing disassembly given that the professional sector often claims a lifetime of 20 years for lighting systems. BE asked: 1. to clarify when this article would apply; 2. if it relates to end of life or repair; 3. to better define "qualified professionals"; 4. to clarify requirements about the availability of spare parts; 5. clarification on safety in case of self-repair; 6. where the instructions would be available; 7 to bring this discussion in the horizontal forum on material efficiency. The Commission clarified that article 4 would apply from 1 September 2020 and that the horizontal work on material efficiency does not yet address specific product requirements. DE highlighted that this is an important issue but that 2020 is difficult and asked the Commission to lay down a roadmap and to specify the concept, as "removability" is a necessary but not sufficient condition to have a circular economy. NL stated that article 4 is a useful article and suggested to add a third step to the removability by the end user or by a professional: the fact that when the light source is not removable, the whole product is considered a light source for the purposes of this regulation. IT commented that the principle is fully shareable, but it should be based on a clear idea of what a light source is. IT shared the proposal made by NL and the concerns from IALD on the electronic components. IT also agreed with BE on the need to clarify the safety conditions for removability and with DE on the need for a roadmap. ANEC welcomed article 4, reported that non-removability is a raising trend (in 2016 from a survey on LED luminaires in 40% of the cases removability was not possible – it was 30% in 2015) and asked to expand the concept from "removable" to "replaceable". EuRIC supported this article, which would mirror the WEEE directive, and suggested to reconsider the wording "readily removable", as the term "readily" used in the battery directive was identified as lacking concreteness. LightingEurope shared the principle and the vision but the timeline is not feasible and there is the need to look into safety issues. An impact assessment on removability would be needed. CEN TC169 informed on the ongoing work in CEN TC10 on circular economy, where this discussion could be developed. EEB expressed strong support and proposed to include a second tier to resolve the concern of timing; EEB considered the safety issue overestimated as we daily replace light bulbs in our homes. As for professional products, EEB suggested, by way of exception, replacing the removability condition with durability, having minimum 40 000 hours lifetime guaranteed. The Commission Services replied that further concrete suggestions would be welcome.

Permanent mechanical damage – SE, NL and DK asked the permanent mechanical damage requirement to be applied not only to the lighting product but also to the containing product. NL added that standards are not needed for this requirement. DK specified that the containing product should not be damaged for verification purposes.

Article 5 – Circumvention

Date of application – BE asked when this article would apply. The Commission Services replied that they would check and as far as possible harmonise the approach for all regulations that are currently under discussion.

Article 6 – Conformity assessment

Technical documentation – BE asked about the reason to have the technical documentation mentioned in this article. The Commission Services replied that it is a common article with regulations for other products and would check.

Article 7 – Verification procedures for market surveillance authorities

No comments.

Article 8 – Indicative benchmarks

No comments.

Article 9 – Repeal

No comments.

Article 10 – Revision

Review drafts – EEB asked to specify that the text to be presented to the Ecodesign Consultation Forum no later than 1 September 2022 would be the draft legislative text.

Article 11 – Entry into force

Alignment with energy labelling – DE asked that the date of application would be synchronised with the new energy labelling for lighting products. The Commission Services confirmed that this is the intention.

Annex III – Energy efficiency requirements

1. Energy efficiency requirements

Table 1 on light sources in scope – ECOS commented that the end loss factors are too high and may undermine the ambition; they will provide proposals. IT asked to expand the line "Other light sources in scope", in order to make clear all the lights that are concerned (especially LED is not mentioned).

Number of tiers – SE asked to add a second tier at 2023 to phase out all non-LED technologies and to consider moving the phase out of T8 to this second tier. CLASP supported a second tier, suggesting, as second-best options, to either apply the same approach of Reg. (EU) 1194/2012 (i.e. that the second tier should apply on a specific date only if evidence is produced by the Commission on its feasibility) or setting the tier 2 date later. NL agreed that a second tier could be a solution for certain aspects, including the T8 phase out and the removability requirement, but, together with AT, opposed setting tiers that would apply after review dates. ECOS suggested that a second tier could include the application of article 4 on removability. This was supported by EEB, which added the reduction of standby power limit to 0.2 and the phase out of all lamps containing mercury.

Correction factors – IT asked to delete "C" in the column "Bonus on C" in Table 2 because it is redundant. DK asked to have the same table in the ecodesign and in the energy labelling acts. CLASP repeated its comment made for Article 2/Annex II about using the "total flux" instead of the "useful flux" because this would simplify the calculation formula proposed in the draft legislation, by removing the correction factors.

Energy savings – CER stated that the quality of the lighting should be taken more into account, as energy savings are not always comparable to the watt output.

T8 phase out – LightingEurope stated that a phase out in September 2020 of T8 lamps is too early and proposed to add a tier for this (e.g. at 2023). LightingEurope added that it could be useful to check in which areas the phase out would cause problems and asked the contractor VHK if they made a sensitivity analysis on the phase out timing. The Contractor replied that they did so and that for every year of delayed phase out, there would a loss of around 2-3 TWh of energy savings. CER and EIM stated that the railway sector is one of the problematic areas and that they need more time for the phase out. SE stated that they would not be happy with delaying the phase out of T8 and that a business model based on LED technologies would improve security, safety and statics. On the contrary, PL stated the delay is necessary because there are no suitable LED replacements for T8 yet when these use controls. Moreover, especially in Eastern countries (which are heavily using T8 lamps) EU funding for energy efficiency has been used recently to install systems with conventional lighting solutions (including e.g. schools) and it would be inefficient to already push end-users to new investment for their replacement. It is also disputable whether LED retrofit solutions can comply with the legislation for light quality and safety in e.g. offices. PL would share an investigation made by Polish market surveillance authorities on 400 lights. While agreeing that removing T8 is very good ambition that needs to happen, IALD supported PL and asked to consider the economic impact when setting the phase-out date, especially for cases that would require changing the lighting system. Lighting control systems recently developed for T8, which are used in Southern and Eastern Europe, would not work well with LED retrofits. DE stated that suitable LED replacements are not available for all applications of LFL T8, e.g. in high ambient temperature, in chemically aggressive atmospheres or in applications that require overvoltage protection. DE added that they are analysing areas where the T8 phase out would create problems, according to feedback from German stakeholders; railways, street lighting, chemical atmospheres with high temperatures and those areas where turning machines are used (as they are impacted by the stroboscopic effect from LEDs). In response to other stakeholders DE stated that they do see major opportunities in terms of energy efficiency (especially in office spaces) and that in many cases there are suitable replacements for T8 lamps. DE stated that its position on LFL T8 was not yet final and referred to the written comments. EEB stated that the phase out of T8 is a unique opportunity to get rid of lamps containing mercury. CLASP supported the proposed phase out of T8 lamps and reported that today most of the new installations are with LED (e.g. the city of Paris has completely converted its metro stations and platforms to LED). CLASP underlined that 2020 is not an early date, because the last time that the EU laid down ecodesign requirement for T8 lamps was in 2010. With reference to the criticism that LED retrofits (which are directional lamps) cannot properly replace T8 lamps (which radiate light 360º), CLASP asked for feedback from LightingEurope in view of the fact that: 1. many members of LightingEurope already today produce LED retrofits of very good quality; 2. there are LEDs today that have double the lumen per watt than T8; and 3. companies like Philips had 68% of their revenue in the third quarter of 2017 from LED. LightingEurope confirmed the trend to use LED in new installations and to produce LED retrofits. However, as the phase out of T8 lamps is happening naturally, they consider it superfluous to regulate them and would leave the timing to the market. AT stressed that the phase out of T8 needs to be agreed now with a clear timing, as it would represent 90% of the energy savings.

Halogen phase out – LightingEurope suggested eliminating the phase out of halogen lamps like G4 and G9, because it would be a small portion of the energy savings and could go against the principle of circular economy as regards luminaires using halogens that could not be refurbished anymore. As for R7s, LightingEurope asked to raise the limit to 5500 lumen. On the contrary, SE and DK strongly supported the phase out of halogens proposed by the Commission. If a second tier is added, AT suggested to phase out all R7s at that moment; AT also asked the Commission to verify that suitable LED replacements exist for G4 and G9 in September 2020. DE proposed for discussion the option to phase out luminaires with G9 and R7s sockets instead of phasing out the lamps.

Colour tuneable lighting – CECED asked to treat differently lighting used for illumination from lighting used for decorative purposes.

Separate control gear – CECED asked to keep in mind that there are applications where the control gear cannot be separated from the overall control board of the appliance and can thus not be measured to check the requirements.

Standby power consumption – DK recommended lower limits, supported by TOPTEN which proposed 0.2 for standby and 0.5 including network standby for light sources and 0.2 standby for control gears. EEB proposed 0.2 for standby, with the option to have it at the second tier if this is added.

2. Functional requirements

Flicker and temporary light artefacts – UK and DK asked for a more ambitious flicker requirement that would cover more than 50% of the population. DE and SE appreciated the flicker requirement and asked to address another temporary light artefact – the stroboscopic effect – by including at least an information requirement. CLASP and ANEC/BEUC supported the proposed requirement for flicker and adding the stroboscopic effect. CLASP suggested that in a possible tier 2 these two requirements could become more stringent and ANEC BEUC asked to pay attention to modulation and frequency, and to define better test methods. IT and LightingEurope asked to remove the requirement for flicker.

The Commission Services replied that the proposed flicker requirement is based on an international standard which is used by Australia and USA and reminded that in 2013 the Commission issued a mandate to CEN-CENELEC to develop standards on flicker and stroboscopic effects but that there is no deliverable yet. According to the latest information, CEN-CENELEC will build the EN standard on the existing international standard (which also covers the stroboscopic effect).

Colour rendering index (CRI) – AT, SE and DK suggested expanding the CRI from R8 (with eight colours) to R9 (by adding red); AT asked to consider as well R14 or R99, with 14 and 99 colours respectively. IALD and ANEC/BEUC supported to use at least R9 (ANEC/BEUC reported that in a recent test they did with R9 and R14, many lamps failed R9). Regarding products with CRI < 80, DE considered it important to put on the light source packaging that such light source is not suitable for household/interior use.

Displacement factor – DK suggested keeping it at 0.5 for P between 5 and 25W, which is in line with CEN/CENELEC standards. 

Colour consistency – ANEC/BEUC asked to reduce the steps of the MacAdam ellipse from six to two or three, reporting that today almost all light sources satisfy this requirement; with fewer steps, the light quality of the products on the market would increase and this would help keeping the same light effect when replacing a lamp in multiple spotlights. SE suggested either setting four steps as an information requirement or applying the "u prime, v prime" method as it was proposed for measuring the white light area.

Lifetime requirement – ANEC/BEUC, EEB and ECOS asked to introduce a functional requirement on lifetime of LED, stating that is necessary to avoid poor quality LED on the market that would hinder the energy savings goals and put some control on self-declarations from producers. ANEC/BEUC stated that especially if the mandatory removability in article 4 is weakened, it would be necessary to inform customers on lifetime. CLASP asked to reconsider the introduction of a minimum lifetime requirement for LED without test which could be set at 15 000 hours. AT and IT stated to be against a lifetime requirement based on declaration only. LightingEurope agreed on the importance of a lifetime requirement but was against having a declared value because if this value is not true the lighting company is not legally liable and the whole exercise would be a loss of time for market surveillance authorities. LightingEurope prefers the approach to motivate its members to offer good products and make honest promises to consumers. On this point AT, based on their market surveillance experience, commented that at least for the domestic segment this is often not the case, especially for lumen maintenance and light quality. Together with DE, AT agreed that industry has enough information on the lifetime of their products and the legislation could require this information to be on the packaging.

SE and DK stated to be in favour of a lifetime requirement.

The discussion on the methods to measure lifetime continued under Annex V.

Functional requirements for separate control gears – CLASP asked to add a displacement factor and a minimum lifetime requirement.

Dimmable light sources and control gears – CECAPI asked to add a functional requirement for dimmable lighting products.

Power definition in Table 4 – IT asked to specify if it is Pon.

3. Information requirements

General comments – LightingEurope stated that the number of information requirements increased and asked to keep it at the level of today; they also asked for flexibility on the way that companies should provide information to market surveillance authorities.

Alignment with energy labelling – NL asked to ensure a good alignment with the energy labelling act and that no extra information requirement is imposed on companies. UK asked in particular to clarify that only one website would be fine for both acts.

Information on the packaging – ANEC/BEUC called for a verification system as regards what is declared on the packaging of lighting products.

Annex IV – Verification procedures for market surveillance authorities

Procedure – DK asked to specify the purpose of the verification of a single unit in (1) and to reconsider the sequence of the procedure, in particular the steps before the test, which comes only at (4) and which is run if the technical documentation is in order. DE supported this point asking to leave flexibility to market surveillance authorities on the order of the procedure (if, for example, they want to test the products before checking the documentation). The Commission Services asked for suggestions for improvement, bearing in mind that this procedure runs across all products regulations.

Number of units to be tested – UK, NL and IT opposed to test only three units of a product whose acquisition costs exceed 500 euro and asked to have always 10 units to test. IT welcomed the reduction from 20 to 10 units to be tested but asked the Commission if the relevance of the tolerance values was verified with the new number (e.g. with a Round Robin test). BE proposed to have three units to test in all cases. The Commission Services replied that they did not run a Round Robin test or similar check.

Tolerance ranges – SE commented that Table 6 is based on the verification tolerances used in Sweden and proposed the other Member States to discuss it and fine-tune it bilaterally. LightingEurope opposed the reduction of the sample units in combination with stricter tolerance ranges, stating that a smaller sample would require higher tolerances, in order to take into account among others the laboratory variability and the production variability. SE opposed to take into account production variability in the tolerances and BE suggested to add a recital to clarify that tolerance ranges are not meant to take account of production variability. DK asked to reconsider the fact to have separate tolerances for Power factor and for Useful luminous flux, because especially in the case of three unit sample, the tolerance would be high (10% + 10%) and could mean a jump of two energy labelling classes. DE stated that the tolerance range for the luminous flux is too narrow, asked for consistent wording in Table 6 (exceed, be less, deviate are used as synonymous) and to state that the determined value should prevail on the declared value. AT noted that the wording for parameters in Table 6, which as regards information requirements is worded more loosely than the other ecodesign requirements and asked to align it to the most stringent approach ("deviate").

Containing products – LightingEurope asked the Commission to confirm that "without permanent mechanical damage" applies to the light source and control gear versus the containing product, when the manufacturer/importer of a containing product is required to provide instructions to market surveillance authorities on how to dismount the lighting product. The Commission Services confirmed so.

"To be used by" date – for retail bulbs for households, IALD proposed to consider to have a date on the product packaging by when the light is guaranteed to keep a good lumen maintenance, as this could save work to market surveillance authorities.

Annex V – Functionality after accelerated endurance testing

(the discussion continued from Annex III on Lifetime)

Reduction of testing time – LightingEurope welcomed the reduction of the 6000 h test to 1000 h, but would favour a 500 h test, to be combined with information requirements on the packaging and the promise of the manufacturer to the consumer. AT agreed to reduce the testing time but commented that for household products a test of 500 h is not enough to avoid products of bad quality on the market. CLASP proposed two texts that would look at survival and lumen maintenance: the first is based on the EPA Energy Star method ISTMT (In‐situ temperature measurement test) + LM80 report which takes two days and is used by industry to test L70. All LEDs manufactured today have an LM80 report, and so the only variable that needs to be established is the LED junction temperature under steady‐state operation, which enables a calculation to determine the 70% lumen depreciation point. The second test is LM‐84 that lasts 3000 hours. DK, SE and NL agreed with LightingEurope that the current 6000 h test is too long and a burden for market surveillance authorities, and would be in favour of exploring the shorter options that CLASP mentioned, even though NL would not favour tests longer than 1000 h. DE asked to keep the 6000 h test because their experience shows that in the first 3000 h of testing no lighting product fails. While agreeing that a test of 6000 h is indeed too long, IALD strongly opposed having short tests that could be too easily passed.

Three tests – LightingEurope criticised the complexity of having to do three tests and underlined that the best protection for consumers comes from market surveillance and simplicity is needed to facilitate market surveillance. ANEC/BEUC asked to clarify if the three tests of 1000 h each mean 3000 h in total, if the tests need to run in sequence and if 10 units per test are needed (for a total of 30 units). NL stated that 30 units would be too many. The Commission Services replied that the tests require 30 units but they are open to reconsider the whole structure of the tests.

Temperature cycling test (test (1)) – LightingEurope believed that very few market surveillance authorities have a climate chamber with the required temperature variation available. CLASP stated that it is an expensive test and proposed to remove it.

Switching cycle test (test (2)) – AT proposed to combine/integrate the switching cycle test (test (2)) with the life test (test (3)) because from their experience, at least for household lamps, the switching test alone is not useful. CLASP supported this and asked to verify in the wording if 1000 h refers to lifetime or to the switching cycle.

Accelerated operation life test (test (3)) – CLASP supported this test as a valuable tool to avoid loopholes for lamps that claim to be exempt for high temperature operation.

Annex VI – Benchmark

No comments.

4.2.Energy Labelling

Article 1 - Subject matter and scope

Luminaires – ANEC/BEUC and TOPTEN stated to be against the removal of the label for luminaires because consumers would miss information on the contained light source and its removability, which should be kept especially if the proposed article 4 on removability in the ecodesign text may be reconsidered. The Commission Services replied that the label would be discontinued but information requirements on the light source apply as required in Annex V.3.2 and that if there would be any change to the proposed article 4 in ecodesign, the information requirements will be adapted accordingly in order to keep at least the same level of information on removability.

Article 2 – Definitions and Annex II – Definitions

Consistency with the definitions in ecodesign – IT reiterated their request to use the same wording for the same definitions in ecodesign.

Final owner – IT asked to delete this definition.

Light source – BE asked to confirm that the definition of light source in the ecodesign and energy labelling is the same. The Commission Services confirmed, adding that the exemptions are different.

Article 3 - Obligations of suppliers & Article 4 - Obligation of dealers

Suggestions for improvement – DE asked to double check the wording to avoid repetitions of the general obligations laid down in the framework regulation.

Sticker for relabelling – DE agreed with the Commission's proposal and stressed the importance of avoiding concurrent labels, in the spirit of the new framework regulation. On the contrary, NL and IT stated that applying a sticker to every product is not a feasible solution: as the framework regulation provides the opportunity to apply other solutions for those products that have the label printed on the packaging, they asked to consider as a compliant solution to not physically relabel every single product; NL stated that a good information campaign could be a solution. IALD stated that, while they see the difficulty to sticker every product, it is necessary to give consumers the right information, especially because lighting products stay on the market for very long (even up to ten years). CLASP observed a contradiction with what was said for lifetime (that a long test for lifetime does not make sense because products on the shelves have a quick turnover). LightingEurope confirmed that a new generation of LED is placed on the market every half year. Independent Retail Europe and EuroCommerce opposed stickers and proposed to have panels/signs on the shelves informing consumers on the rescaling for lamps. LightingEurope disagreed with the Commission's proposal.

Side for the label – IT asked to remove the obligation to have the label printed on the side that would face the consumer in the shop, because they find it confusing and a verification burden for surveillance authorities.

Label for business-to-business – LightingEurope asked to have the physical label only at final points of sale for business-to-business customers. The Commission Services confirmed that this is the intention.

Suppliers of containing products – NL and CECED asked to confirm that suppliers of containing products are not subject to the obligations laid down in article 3.1 but only to article 3.2. In addition DK asked to confirm that Annex V.4 on EPREL does not apply to containing products. The Commission Services confirmed on both points that this is the intention, reminding that only the information on the contained light source goes into the EPREL database and it is the responsibility of the manufacturer/importer of the lighting product to comply with this. IT asked what happens if a containing product that is subject to EPREL (e.g. fridges for domestic use) changes the type of lamp: would the manufacturer/importer of the fridge need to update the technical documentation in EPREL just for the light? The Commission Services replied that this is true for all components of a fridge that would bring changes in the technical documentation.

Eco-lamps – EEB asked to retain the possibility that is in the current legislation to call a lamp "eco-lamp", but making the conditions more stringent.

Article 5 – Measurement methods

No comments.

Article 6 – Verification procedure for market surveillance purposes

No comments.

Article 7 – Revision

No comments.

Article 8 – Repeal

No comments.

Article 9 – Entry into force and application

Derogation to 30 days – DE stated to be against and asked to apply the standard 14 days laid down in the framework regulation. Independent Retail Europe and EuroCommerce stated instead that minimum six months would be needed and asked if 30 days are working days. NL shared the concerns of Independent Retail Europe and EuroCommerce.

Annex I – Exemptions

Range hoods – CECED requested to exempt range hoods, as these products already have a label for the contained light source.

Annex II – Definitions

See Article 2.

Annex III – Label for light sources

QR code – IT and EEB asked to make it clear that the QR should link to EPREL. LightingEurope asked not to make the QR code mandatory, as over time the link could be broken or the information moved elsewhere; moreover if the printed link links to EPREL it would not be appropriate for products that are sold also outside the EU. The Commission Services confirmed that the QR code would link to EPREL and acknowledged that products with that QR code could be sold outside the EU where the label is not mandatory. The Commission Services also clarified that the inclusion of a QR code cannot be on a voluntary base and stated that it is intended to be a useful tool for consumers.

Standby consumption – TOPTEN proposed to eliminate the consumption per 1000 h and to put instead the actual consumption, including the standby consumption, and for the luminaire label (once it is decided to continue it), the control gear consumption. DK asked to include the standby consumption in the 1000 h value.

Label design – DE stated not to be happy with the proposed design and would share suggestions. ANEC/BEUC asked for information about the intention of the Commission to run a consumers' survey that would look into the label design and to be informed about the outcome. The Commission Services replied that they will share the terms of reference.

Annex IV – Energy efficiency classes and calculation method

Resulting classes – IT commented that today (not in September 2020) products would all be in classes G or F. LightingEurope considered classes A and B too ambitious. TOPTEN asked to add standby consumption in the calculation and to add an allowance for “low lumen-low voltage” bulbs, in order to discourage consumers buying high lumen bulbs just because these are in top classes. CLASP congratulated the Commission for the proposed classes, reminded that in 2017 a LED bulb with 200lm/W exists (the Dubai lamp) and supported TOPTEN on having standby consumption in the calculation.

Time perspective – UK suggested that a sales estimation after eight years and not after ten years would be more appropriate in view of the review planned after ten years, especially if top classes do not fill up as expected. The Consultant replied that estimations are based on data provided by industry and would not find it surprising if the opposite happens (that classes fill up quicker than estimated).

Correction factors – see comments on correction factors made for Annex III of the ecodesign proposal.

Annex V – Product information

Content of EPREL – LightingEurope asked that only information on energy labelling should be in EPREL and not on ecodesign, as EPREL is so far thought for labelling only. EEB stated that instead it would be a good occasion to have ecodesign and energy labelling information already in one system. The Commission Services clarified that the approach of the Commission is to align the requirements in the two texts to avoid duplication when it is the same information.

Luminaires in EPREL – LightingEurope requested to exempt luminaires from EPREL, as in the draft text it is proposed to discontinue the energy label for luminaires. The Commission Services stated that EPREL applies from 1 January 2019 which is before the proposed date to discontinue the label for luminaires (1 September 2020) and thus in principle luminaires are in scope of EPREL.

More than one lighting product in a containing product – LightingEurope asked to clarify if, in the case of a containing product such a luminaires with several light sources, the information for all light sources needs to be shown. The Contractor replied that making a list of the contained lighting products does not seem to be a big burden.

Information to be put on the packaging of a containing product – LightingEurope opposed to have on the packaging the sentence 3.2(b) about the information on the contained light source, because it would need to be in 24 languages; it would be a burden especially for small packaging and for products containing more than one light source. DE suggested replacing the sentence with the arrow proposed for the front packaging. The Commission Services replied that they will look into this issue.

Small packaging – BE asked to remove the last sentence of 3.1 about placing a label in proximity to the packaging in case of small packaging, as this provision would only create confusion.

Annex VI – Information to be provided in the case of distance selling, except distance selling on the Internet

&

Annex VII – Information to be provided in the case of distance selling through the Internet

&

Annex IX – Displaying the energy class and the range of efficiency classes in visual advertisements and in promotional material

Image – DE said that they would send suggestions for the design. CECED asked to ensure consistency within all the ecodesign acts and use the same arrow. The Commission Services replied that this is the intention.

Annex VIII – Verification procedure for market surveillance authorities

See comments for Annex IV of the ecodesign proposal.

5.AOB

UK asked whether the Commission could already give information on the Ecodesign Consultation Forum meetings that will be held in the first quarter of 2018.

The Commission Services replied that there might be a meeting on computers. For EPREL, meetings for each of the three main user groups (i.e. suppliers, market surveillance authorities and public) are scheduled for March 2018.

IT asked the Commission to provide a schedule in one table of all meetings until mid-2018 at one of the next meetings in December 2017. ECOS extended the requests for the meetings for preparatory studies.

The Commission Services will give indicative information but no dates.

LightingEurope asked information about the open public consultation that the Commission would run according to the Better Regulation procedure.

The Commission Services explained the procedure and specified that the consultation would cover all product groups under revision.

IALD asked about the work on lighting systems.

The Commission Services replied that it is not their intention to work on lighting systems before the ongoing review for lighting products is concluded.

Comments to the working documents are due by 26 January 2018.

  

Attendance List

|  |  |
| --- | --- |
| Commission Services | |
| DG ENER | C.3 |
| DG ENV | B.1 |

|  |  |
| --- | --- |
| EU Member States | |
| AT | Austrian Energy Agency |
| BE | FPS Economy, SME, Selfemployed and Energy |
| BG | Permanent representation to the EU |
| CZ | State Energy Inspection Authority |
|  | Ministry of Industry and Trade |
| DE | Federal Environment Agency |
|  | Federal Institute for Materials Research and Testing |
|  | Federal Ministry for Economic Affairs and Energy |
|  | Federal Ministry for the Environment, Nature Conservation, Building and Nuclear Safety |
|  | Bavarian State Ministry for Environment and Consumer Protection |
|  | Baden Württemberg Ministry of Environment, Climate Protection and the Energy Sector |
| DK | Danish Energy Agency |
| EE | Estonian Ministry of Economic Affairs and Communications |
| FI | Energy Authority |
| FR | Ministère de l'énergie et du développement durable |
| IE | Enterprise Ireland, Competitiveness |
| IT | ENEA |
| NL | Netherlands Enterprise Agency |
| PL | Ministry of Energy |
| SE | Swedish Energy Agency |
| UK | Department for Business, Energy & Industrial Strategy, Sustainable Energy using Products team, Home and Local Energy |
|  | Department of Energy and Climate Change |
| EEA countries | |
| CH | Swiss Federal Office of Energy |
| NO | Norwegian Water Resources and Energy Directorate |

|  |  |
| --- | --- |
| Organisations | |
| AIE | EIM |
| ANEC/ BEUC | EucoLight |
| CECAPI | EuRIC |
| CECED | EuroCommerce |
| CEN/TC 169 | IALD |
| CER | Independent Retail Europe |
| CLASP | LightingEurope |
| ECOS | ORGALIME |
| EEB | TOPTEN |
| EFIC | VHK |

Annex 6: Employment and Market in the lighting sector

Preamble

This Annex groups information regarding enterprises, revenues and employment involved in the lighting business. The intended focus is EU28, but it is not always possible to split revenues and employment in extra-EU amounts and EU-amounts.

Although the lighting regulations also regard some aspects of luminaires, control gears and lighting controls, their main scope is light sources. However, data on enterprises, revenues and employment for light sources in scope are typically mixed with those for light sources out-of-scope, luminaires, control gears, lighting controls, lighting systems and lighting services. It is difficult to exactly relate the scope of the regulations to EU28 revenues and employment figures.

Summary

As for manufacturers of light sources, in 2015, 1.7 billion light sources for general lighting purposes were sold in EU28 with a total estimated purchase cost for consumers of EUR 14.8 billion, leading to EUR 9.7 billion revenues for industry, EUR 2.1 billion for the wholesale sector, EUR 1.9 billion for the retail sector and EUR 1.2 billion governmental tax incomes. Additionally, costs for installation and maintenance were of EUR 3.0 billion and EUR 5.0 billion
[1](#footnote1)
.

In 2015, the total number of jobs (inside and outside of EU28) related to the sale of light sources in EU28 is estimated to be 234 000, of which 194 000 in industry (including manufacturing, OEM and services) and 39 000 in trade (wholesale and retail). Additionally, 30 000 jobs for installers and 50 000 jobs for maintenance are estimated
[2](#footnote2)
.

The EU28 employment is estimated to amount to 95 000 jobs, of which 60 000 jobs in industry (including manufacturing, OEM suppliers and services) and 35 000 in trade. The major suppliers of light sources in EU28 are Philips Lighting
[3](#footnote3)
, Ledvance/Osram, General Electric (GE) Lighting
[4](#footnote4)
 and Feilo-Sylvania. Together, in the EU28 they signify EUR 3 billion of estimated revenue from the sale of light sources for general lighting and 15 000 jobs (manufacturing only)
[5](#footnote5)
.

With the ongoing rapid shift to LED lighting, manufacturers of lighting-related electronics are required to adjust from electronic control gears for classical lighting technologies to drivers for LEDs. Less efficient electro-magnetic control gears are phased out from the market since 2017 and have been replaced by more efficient, high-frequency electronic ones. These manufactures have a dynamic business also for the increasing trend to have ‘smart lights" with new features.

Retailers and wholesalers are faced with a highly dynamic market: first there was the shift from incandescent light bulbs to halogen and fluorescent lamps; now, with the uptake of LEDs, new models are being introduced on the market at a high frequency. Some retailers have decided to sell only LED lamps
[6](#footnote6)
. Sales on internet are increasing. The European associations for retailers are Independent Retail Europe and EuroCommerce.

Details from modelling

The data regarding revenues and related employment in the lighting business have been derived from the MELISA model for the BAU scenario.

|  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Economic and employment results of MELISA for BAU: EU28 totals and subdivision in Non-LED and LED. | | | | | | | | |
| EU28 Totals (all sectors) |  | 1990 | 2010 | 2015 | 2020 | 2025 | 2030 |
| Sales | mln units | 2112 | 2353 | 1702 | 1737 | 929 | 737 |
| Of which (o/w) Non-LED |  | 2112 | 2345 | 1330 | 604 | 288 | 140 |
| o/w LED |  | 0 | 8 | 372 | 1133 | 641 | 597 |
| Stock | mln units | 5576 | 10045 | 11360 | 12459 | 13492 | 14635 |
| o/w Non-LED |  | 5576 | 10031 | 10615 | 7320 | 4300 | 2709 |
| o/w LED |  | 0 | 14 | 745 | 5138 | 9192 | 11926 |
|  |  |  |  |  |  |  |  |
| Purchase Cost | mln euros | 4623 | 10428 | 14849 | 13078 | 8346 | 8264 |
| o/w Non-LED |  | 4623 | 10143 | 7099 | 3840 | 2070 | 1100 |
| o/w LED |  | 0 | 285 | 7750 | 9238 | 6277 | 7164 |
| o/w Industry Revenue | mln euros | 2886 | 5980 | 9703 | 9306 | 6308 | 6438 |
| o/w Non-LED |  | 2886 | 5788 | 4076 | 2508 | 1451 | 806 |
| o/w LED |  | 0 | 192 | 5626 | 6798 | 4857 | 5632 |
| o/w Wholesale Revenue | mln euros | 752 | 1925 | 2078 | 1531 | 917 | 853 |
| o/w Non-LED |  | 752 | 1896 | 1303 | 608 | 289 | 137 |
| o/w LED |  | 0 | 28 | 775 | 924 | 628 | 716 |
| o/w Retail Revenue | mln euros | 709 | 1776 | 1877 | 1374 | 867 | 827 |
| o/w Non-LED |  | 709 | 1754 | 1211 | 563 | 271 | 129 |
| o/w LED |  | 0 | 22 | 666 | 811 | 596 | 698 |
| o/w Taxes (VAT) | mln euros | 277 | 747 | 1192 | 866 | 254 | 146 |
| o/w Non-LED |  | 277 | 705 | 509 | 162 | 58 | 28 |
| o/w LED |  | 0 | 42 | 683 | 705 | 196 | 118 |
| Installation Cost | mln euros | 2524 | 3975 | 3009 | 3067 | 2599 | 2525 |
| o/w Non-LED |  | 2524 | 3973 | 2705 | 1964 | 1189 | 651 |
| o/w LED |  | 0 | 2 | 304 | 1103 | 1411 | 1873 |
| Maintenance Cost | mln euros | 1852 | 4509 | 4981 | 5611 | 6349 | 7183 |
| o/w Non-LED |  | 1852 | 4507 | 4705 | 3815 | 2424 | 1362 |
| o/w LED |  | 0 | 1 | 275 | 1796 | 3925 | 5821 |
| Purchase related Jobs | thousands | 73 | 157 | 234 | 215 | 144 | 146 |
| o/w Non-LED |  | 73 | 153 | 107 | 62 | 35 | 19 |
| o/w LED |  | 0 | 4 | 127 | 153 | 110 | 127 |
| o/w Industry | thousands | 58 | 120 | 194 | 186 | 126 | 129 |
| o/w Non-LED |  | 58 | 116 | 82 | 50 | 29 | 16 |
| o/w LED |  | 0 | 4 | 113 | 136 | 97 | 113 |
| o/w Wholesale | thousands | 3 | 8 | 8 | 6 | 4 | 3 |
| o/w Non-LED |  | 3 | 8 | 5 | 2 | 1 | 1 |
| o/w LED |  | 0 | 0 | 3 | 4 | 3 | 3 |
| o/w Retail | thousands | 12 | 30 | 31 | 23 | 14 | 14 |
| o/w Non-LED |  | 12 | 29 | 20 | 9 | 5 | 2 |
| o/w LED |  | 0 | 0 | 11 | 14 | 10 | 12 |
| Installation Jobs | thousands | 25 | 40 | 30 | 31 | 26 | 25 |
| o/w Non-LED |  | 25 | 40 | 27 | 20 | 12 | 7 |
| o/w LED |  | 0 | 0 | 3 | 11 | 14 | 19 |
| Maintenance Jobs | thousands | 19 | 45 | 50 | 56 | 63 | 72 |
| o/w Non-LED |  | 19 | 45 | 47 | 38 | 24 | 14 |
| o/w LED |  | 0 | 0 | 3 | 18 | 39 | 58 |

An advantage of these figures from the MELISA model is that they are only for light sources in the scope of the existing regulations. E.g. special purpose lamps, automotive lamps, luminaires, non-integrated ballasts/controlgears/drivers, lighting controls (switches, dimmers, sensors, etc.), lighting systems, and lighting services are NOT included.

A major drawback of the figures is that they do not distinguish between jobs inside EU28 and jobs outside EU28. A significant portion (60-70%) of the industry jobs reported above is expected to be outside EU28.

The above figures regard only direct jobs. Indirect effects are not included, e.g. lighting business employees spending their income, or lighting consumers spending the money saved on energy costs (due to higher efficiency lamps) on other products, and thus creating indirect jobs elsewhere. These indirect jobs might well be 3 to 5 times the quantity of direct jobs associated with lighting, but there is no agreed quantification method.

Eurostat Business Statistics

The data in 
[Table 61](#_Ref450667200)
 have been derived from Eurostat Business statistics for NACE rev.2, group C 274: Manufacture of electric lighting equipment 
[7](#footnote7)
.

In 2014, Eurostat reports 7640 enterprises in EU28 that are involved in the manufacture of electric lighting equipment. The large majority of these (5859) employs 9 persons or less. Only 91 enterprises (> 250 employed) are not SMEs.

These enterprises employ a total of 152800 persons, of which slightly less than half (70600) in large enterprises with over 250 employees.

The annual turnover of these enterprises is 28.6 billion euros, of which more than half (17.1 billion euros) is realized in the large enterprises.

The advantage of these data is that they relate only to the EU28. However, they also include e.g. manufacturing of luminaires, special purpose lamps and automotive lamps, and consequently are only partly related to the scope of the existing lighting regulations. It is unknown in how far they include ballasts/control gears/drivers, lighting systems, lighting services and LED lighting products. As there is no separate NACE code for LED lighting products yet, their suppliers might not always be included under lighting manufacturers. Some enterprises involved in lighting might have been registered under manufacture of electronic products (which form part of the manufacture of computer, electronic and optical products, Division 26).

Another doubt is how companies are handled that have lighting as their main business but also manufacture other products, or companies that have another main business but also produce lighting products.

|  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
| Table 61: Eurostat statistics for NACE rev. 2 group C 274: Manufacture of electric lighting equipment;  (Industry by employment size class (NACE Rev. 2, B-E) [sbs\_sc\_ind\_r2], accessed May 2018) | | | | | | | | | |
| EU28 totals | 2008 | 2009 | 2010 | 2011 | 2012 | 2013 | 2014 | 2015 | variation 2008-2014 | |
| Number of enterprises | 8610 | 8197 | 8360 | 7900 | 7545 | 7265 | 7640 |  | -11% | |
| o/w with 0-9 employed | 6469 | 6186 | 6115 | 5994 | 5656 | 5423 | 5859 |  | -10% | |
| o/w with 10-19 employed | 920 | 809 | 889 | 823 | 831 | 776 | 706 | 768 | -23% | |
| o/w with 20-49 employed | 691 | 677 | 634 | 598 | 594 | 591 | 596 |  | -14% | |
| o/w with 50-249 employed | 417 | 400 |  | 390 | 374 | 385 | 390 |  | -6% | |
| o/w with > 250 employed | 106 |  |  | 95 | 90 | 89 | 91 | 96 | -16% | |
| Number persons employed | 185600 | 161600 | 158700 | 158500 | 153900 | 154800 | 152841 | 155553 | -18% | |
| o/w with 0-9 employed | 17400 | 16200 | 15500 | 15200 | 15100 | 14400 | 15157 |  | -13% | |
| o/w with 10-19 employed | 12600 | 10900 | 12600 | 11700 | 11800 | 10500 | 9454 |  | -25% | |
| o/w with 20-49 employed | 21200 | 20100 | 19600 | 19200 | 18700 | 18400 | 18056 |  | -15% | |
| o/w with 50-249 employed | 42000 | 41300 | 38200 | 39300 | 38700 | 40600 | 39558 |  | -6% | |
| o/w with > 250 employed | 92400 | 73100 | 72000 | 73100 | 69700 | 70900 | 70617 |  | -24% | |
| Turnover (mln EUR ) | 27844 | 23718 | 25533 | 27681 | 27727 | 28163 | 28624 | 29552 | +3% | |
| o/w with 0-9 employed | 1556 | 1378 | 1206 | 1488 | 1500 | 1320 | 1506 | 1375 | -3% | |
| o/w with 10-19 employed | 1418 | 1268 | 1151 | 1527 | 1631 | 1297 | 1132 | 1367 | -20% | |
| o/w with 20-49 employed | 2986 | 2417 | 2533 | 2621 | 2501 | 2646 | 2663 | 2628 | -11% | |
| o/w with 50-249 employed | 6076 | 5249 | 5118 | 5668 | 5987 | 6204 | 6238 | 6560 | +3% | |
| o/w with > 250 employed | 15808 | 13407 | 15454 | 16377 | 16107 | 16696 | 17085 | 17622 | +8% | |

Eurostat ProdCom Statistics

Eurostat data up to 2013 
[8](#footnote8)
 regarding production and trade of light sources and ballasts have been extensively reported in the Lot 8/9/19 study 
[9](#footnote9)
. In the meantime 2014 data could be added, and the figures related to the economic values of production, import and export are reported below (for sales quantities in number of units see the reference 154).

These data are exclusive most automotive lamps. Also Eurostat data do NOT include LED lamps, because there is no specific NACE product code for these lamps yet. In 2014, LED lamps have a significant economic value
[10](#footnote10)
. Overall, the reliability of these Eurostat data is low and outcomes are hardly comparable to industry data in MELISA.

 

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Figure 32 Eurostat ProdCom data for light sources. EU28 total values in mln EUR for production, import and export.

Stage 6 review

In the report on the review of stage 6 of CR 244/2009, the estimated number of European jobs involved in the phase-out of mains-voltage non-directional halogen lamps was estimated around 6800, including a loss of 4200 direct jobs in industry, a loss of 3100 indirect jobs 
[11](#footnote11)
 for suppliers and subcontractors and a positive effect around 500 jobs.

Philips Lighting

Philips Lighting is one of the major players on the EU28 lighting market. According to the full annual report over 2015
[12](#footnote12)
, Philips, including Healthcare, Consumer Lifestyle and Lighting, had:

-Sales
   
   
   24.2 bn EUR worldwide 
   
   of which (o/w) 7.9 bn in EMEA 
[13](#footnote13)
.

-Employed
   
   104 200 persons worldwide
   
   o/w 39 903 in EMEA.

oo/w in Production
   
   
   
   44%

oo/w in R&D
   
   
   
   
   
   11%

oo/w Other
   
   
   
   
   
   
   32%

oo/w 3rd party workers
   
   13%

-R&D centres
   
   60 worldwide
   
   
   
   
   
   o/w 28 in EMEA.

-Manufacturing sites
   95 worldwide
   
   
   
   o/w 35 in EMEA.

-R&D expenses
   1.9 bn EUR worldwide

Considering only Philips Lighting:

-Sales
   
   
   7.4 bn EUR worldwide 
   of which (o/w) 2.2 bn in Western Europe

oo/w Light Sources & Electronics
   
   56% 
[14](#footnote14)

oo/w Consumer Luminaires
   
   
   
   
   7%

oo/w Professional lighting solutions
   37%

-Sales decline
   
   -3% comparable sales 2015 vs. 2014; -3% 2014 vs. 2013

-Employed
   
   33 600 persons worldwide in 2015 (FTE)

-Employment decline
   -11% in 2015 vs. 2014; -2% 2014 vs. 2013

-R&D expenses
   315 mln EUR worldwide

The decline of 3% in comparable sales is due to the decline of conventional lighting. This is compensated for a large part by an increase of 25% in LED-related sales that in 2015 account for 43% of total lighting sales (was 34% in 2014).

The number of persons employed by Philips Lighting in EMEA is not reported but can be estimated around 13 000, assuming the same EMEA/World ratio for Philips Lighting as for Philips as a whole. In 2015, EU28 employment for Philips Lighting could be around 10 000 – 12 000.

Philips states that the conventional lamps industry is highly consolidated, with GE and OSRAM as main key competitors. The LED lighting market is very dynamic, with new competition from Asia and new players from the semiconductor and building management sectors. The luminaires industry is fragmented.

Since 2008, many of the Philips lighting factories in Western Europe have reduced personnel, been sold, or closed. Production has moved in particular to Poland, where Philips Lighting employed 9000 persons in 2013 
[15](#footnote15)
, and to Asia (China, Malaysia).

As regards the Philips Lumileds and Automotive Lighting business, in January 2016 it was announced that the acquisition of a 80.1% share by a consortium led by GO Scale Capital has been cancelled. The CFIUS (Committee of Foreign Investment in the United States) did not grant clearance for this transaction. Anyway Philips is still actively discussing the sale of this combined business and expects a transaction to be completed in the year 2016.

From February 2016 Philips created a stand-alone structure for Philips Lighting. In the first half of 2016 they expect to announce the separation of the Lighting business. Both initial public offering and a private sale are reviewed options. So, essentially, Philips wants to get out of the lighting business.

OSRAM

Osram is one of the major players on the EU28 lighting market, and the main competitor of Philips. The following data have been derived from the OSRAM Licht Group annual report on fiscal 2015
[16](#footnote16)
:

-Revenue
   5.574 bn EUR worldwide
   
   

oOf which (o/w) 2.29 bn EUR in EMEA

oo/w 0.79 bn EUR in Germany

oo/w Speciality Lighting (SP)
   
    1.85 bn EUR 
[17](#footnote17)

oo/w Opto Semiconductors (OS)
    1.29 bn euros

oo/w Digital Systems (DS)
   
   
    not reported

oo/w Lighting Solutions (LS)
   
    0.96 bn euros

oo/w Lamps (LP)
   
   
   
   
   
   
    2.00 bn euros

-Decline
   -1% comparable sales 2015 vs. 2014

-Employed
   33 800 persons worldwide (FTE) 
   

oo/w 13 800 in EMEA

oo/w 8 900 in Germany

oo/w Speciality Lighting (SP)
   
   
    6 100 persons

oo/w Opto Semiconductors (OS)
   
    9 200 persons

oo/w Digital Systems (DS)
   
   
   
    3 000 persons

oo/w Lighting Solutions (LS)
   
   
    1 900 persons

oo/w Lamps (LP)
   
   
   
   
   
   
   
   10 100 persons

oo/w production and service
   
   
   
   24 300 persons

oo/w selling
   
   
   
   
   
   
   
   
   
    4 300 persons

oo/w administration and general
    1 800 persons

oo/w research and development
    2 400 persons

-Decline

o-2.6% employment 2015 vs. 2014

o-17% employment 2015 vs. 2011
[18](#footnote18)

In 2015, earnings were positive for SP (EUR 245 million) and OS (EUR 230 million), but negative for LS (EUR -42 million) and LP (EUR -48 million).

Traditional lamp business contracted by 11.7% while LED lamps business grew by 26.8%.

Under the Osram Push program, the company’s target is to reduce jobs by 7 800 in the period 2014 – 2017 (o/w 2 400 have now been realized), and to reduce costs by 1 EUR 300 mln over the same period. Transformation costs will be EUR 450 mln over the same period.

In part due to this program, but also in earlier years, many of the Osram factories in Western Europe have reduced personnel. An example is the plant producing fluorescent lamps in Augsburg that employed 2200 workers in 2008, 1550 in 2012, 1200 in 2014 and is down to 1023 in November 2015. The plant will probably be split off from the company and sold, maybe into Chinese hands
[19](#footnote19)
. Other factories in Germany, France and Italy show similar destinies.

The traditional technology lighting sector of Osram was as of January 2016 for sale, and the company will concentrate on LED lighting. Up to 2020, Osram intends to invest EUR 3 billion in LED lighting, including EUR 2 billion for research and development and EUR 1 billion for a new LED-chip plant in Malaysia 
[20](#footnote20)
. New investments of the Digital Systems division are also being made in Plovdiv, Bulgaria, where a new 900 jobs plant is expected to start functioning in 2017 
[21](#footnote21)
 and in Nitra (Slovakia) 
[22](#footnote22)
.

General Electric (GE)

General Electric (US-based) and consolidated affiliates are active in Power, Renewable Energy, Oil & Gas, Energy Management, Aviation, Healthcare, Transportation and Appliances & Lighting. GE is indicated by Philips and by Osram as one of the main competitors in the EU lighting business.

The total 2015 revenue for all these sectors is reported as 109 billion dollars
[23](#footnote23)
, of which Appliances & Lighting covers 8.8 billion. Of the latter, 72% is lighting and 3% of the revenues come from Europe.

Consequently, GE revenues from lighting in EU in 2015 can be estimated as 8800\*72%\*3% = 190 mln US dollars = 170 mln euros
[24](#footnote24)
. Compared to Philips and Osram that are each around 2 billion euros, this is modest.

In 2015, GE Appliances & Lighting employed 24 000 persons worldwide.

GE’s European lighting factories are mainly in Hungary and in 2008 are reported to have employed around 10 000 persons, but this is now probably down to less than 6 000. The main plant is in Nagykanizsa and employed 4 200 people in 2015.

Havells-Sylvania

Havells was an India-based company that has its main activities in cables (42% of stand-alone turnover), switchgears, electric consumer durables and Lighting & Fixtures.

The total 2015 net sales (consolidated) are reported as 8569 crores
[25](#footnote25)
 = 1139 mln euros, of which 4072 crores = EUR 541 mln for Lighting&Fixtures. Havells itself realized EUR 98 mln of this while affiliate Sylvania was good for EUR 443 mln.

These data are worldwide; no details are reported on revenues from Europe.

In spring 2016 Havells sold the majority of Sylvania shares to Chinese Feilo, so that the companies name is now Feilo Sylvania.

Sylvania’s main European lighting factories are in Tienen (B), Erlangen (D), Newhaven (UK) and St Etienne (F), employing a total of 600-800 employees in 2015. This includes also luminaire production of the Concord and Lumiance brands.

The Tienen plant, producing halogen-, HID- and LED-lamps reduced personnel in recent years, passing from over 600 people in 2008 to the current 300. The Erlangen plant met a similar destiny, passing from 580 people in 2007 to the current 200.

Concluding on revenues

Philips Lighting reports revenue of EUR 2.2 billion in Western Europe of which 56% for light sources and electronics, i.e. EUR 1.23 billion. For the entire EU28, including parts of Central and Eastern Europe, the total revenue from light sources could be around EUR 1.5 billion.

Osram reports a revenue of EUR 2.3 billion in EMEA, of which 50% can be estimated to be related to light sources (LP-division and part of OS-division), i.e. EUR 1.15 billion. For EU28 this will be slightly smaller than for EMEA, around EUR 1.0 billion.

The contribution of GE-Lighting and Sylvania to light source related revenues can be estimated in maximum EUR 0.5 billion.

Summing these contributions, a total EU28 revenue for light sources around EUR 3 billion can be estimated for the four main suppliers, of which around 40% LED-related, i.e. EUR 1.8 billion for conventional light sources and EUR 1.2 billion for LED light sources. Note however that these suppliers only represent a share of the market.

Concluding on employment

Philips Lighting is estimated to employ 10 000 – 12 000 persons in EU28. Osram employment in EU28 is similar (between 8 900 in Germany and 13 800 in EMEA). GE-Lighting and Sylvania can be estimated to employ 7000 persons in EU28.

This sums up to around 30 000 direct industry jobs for the four main suppliers, but probably less than 50% of these (15 000) are related to manufacturing of light sources in the scope of the regulation (others are for e.g. luminaires, lighting systems, speciality lamps, automotive lamps). Assuming that indirect jobs at suppliers, subcontractors, servicers are twice this amount
[26](#footnote26)
, a total of 45 000 industry jobs results for the four main suppliers. Extending this to all EU28 suppliers of light sources, this could become around 60 000 jobs in EU28 related to light sources (excluding luminaires).

Involvement of EU companies in LED light source production

The text and tables presented below have been taken from a 2017 US DoE report
[27](#footnote27)
 on the LED market. This is not a full survey of EU companies involved in production of LED lighting products: only key companies as identified by US DoE are included, but it gives a rough idea of the spread of activities over America, Asia and Europe.

Only few EU companies are involved in manufacturing of basic LED components (dies, packages), and even these have their main production sites in Asia.

The EU share of LED-related activities is larger for production equipment (epitaxial growth; vapour deposition), wafer processing-, test- and inspection-equipment.

From US DoE report:

LED, lamp, and luminaire manufacturing are global enterprises with a global supply chain. Some geographical production trends can be identified; however, many of the input materials and semiconductor processing tools are produced worldwide. Table 6.2 and Table 6.3 highlight the global nature of SSL manufacturing by listing some of the key companies in each major geographical region involved in the manufacturing of LED-based SSL products and in the supply of equipment and materials to that market. These tables categorize geographical location based on company headquarter location and may not accurately reflect the balance of manufacturing activity.

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Annex 7: The Ecodesign and Energy Labelling Framework

The Ecodesign Framework Directive and Energy Labelling Framework Regulation are framework rules, establishing conditions for laying down product-specific requirements in regulations adopted by the Commission. The Commission's role in the implementation of delegated and implementing acts is to ensure a maximum of transparency and stakeholder participation in presenting a proposal, based on generally accepted data and information, to the European Parliament and Council for scrutiny. 
[Figure 33](#_Ref509853933)
 gives an overview of the legislative process.

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Figure 33: Overview of the legislative process

Energy labelling delegated acts are usually adopted in parallel with ecodesign implementing measures laying down minimum energy efficiency requirements for the same product group. This is done to ensure a coherent impact of the two measures: energy labelling should reward the best performing products through mandatory rating, while ecodesign should ban the worst performers.

The process starts with establishing the priorities for Union action in this area. Priority product groups are selected based on their potential for cost-effective reduction of greenhouse gas emissions and following a fully transparent process culminating in working plans that outline the priorities for the development of implementing measures.

A first list of priority product groups was provided in Article 16 of the Ecodesign Framework Directive in force at that time
[28](#footnote28)
. Subsequently, the (first) Ecodesign Working Plan 2009-2011
[29](#footnote29)
, the (second) Ecodesign Working Plan 2012-2014
[30](#footnote30)
 and the Ecodesign Working Plan 2016-2019 were adopted by the Commission after consultation of the Ecodesign Consultation Forum (composed of MS and stakeholder experts).

The products listed in the three plans (1st working plan: 1-10; 2nd working plan: 11-18; 3rd working plan: 19-25) can be found in 
[Table 62](#_Ref509853987)
.

Table 62: Overview of products listed in the 3 Working plans

|  |  |
| --- | --- |
| 1.Air-conditioning and ventilation systems (commercial and industrial) | 14.Enterprises' servers, data storage and ancillary equipment |
| 2.Electric and fossil-fuelled heating equipment | 15.Smart appliances/meters |
| 3.Food preparing equipment (including coffee machines) | 16.Lighting systems |
| 4.Industrial and laboratory furnaces and ovens | 17.Wine storage appliances (c.f. Ecodesign regulation 643/2009) |
| 5.Machine tools | 18.Water-related products |
| 6.Network, data processing and data storing equipment | 19.Building automation control systems |
| 7.Refrigerating and freezing (professional) | 20.Electric kettles |
| 8.Sound and imaging equipment (incl. game consoles) | 21.Hand dryers |
| 9.Transformers | 22.Lifts |
| 10.Water-using equipment | 23.Solar panels and inverters |
| 11.Window products | 24.Refrigerated containers |
| 12.Steam boilers ( < 50MW) | 25.High- pressure cleaners |
| 13.Power cables |  |

There were also a number of conditional products listed in the 2nd Working Plan that the Commission committed to study closer before deciding to launch full preparatory work (such as thermal insulation, power generating equipment). In the 3rd Working Plan, the Commission committed to assess certain ICT products in a separate track to determine the best policy approach for improving their energy efficiency and wider circular economy aspects and a potential inclusion in the Ecodesign working plan.

Once the product group has been selected, a preparatory study is undertaken by an independent consultant, also involving extensive technical discussions with interested stakeholders. The preparatory study follows the MEERP. Subsequently, the Commission's first drafts of ecodesign and energy labelling measures are submitted for discussion to the Consultation Forum, consisting of MSs' and other stakeholders' representatives.

After the Consultation Forum, the Commission drafts an impact assessment, which after approval of the IAB is taken forward to the inter-service consultation together with draft implementing measures. In this and subsequent steps, the Parliament's functional mailboxes for delegated/implementing acts are copied on each message from the Commission services. After the inter-service consultation, stakeholders are alerted when the draft measures are published in the WTO notification database.

After the WTO notification phase is completed, the two procedures follow different paths. The draft energy labelling delegated act is discussed in a MS Expert Group where opinion(s) are expressed and consensus is sought but no vote is taken. The draft ecodesign measure is submitted for vote to the Regulatory Committee of MS experts.

The European Parliament and Council have the right of scrutiny for which a period of up to four months, if requested, is foreseen. Within this time the co-legislators can block the adoption process by the Commission. Parliament committees sometimes discuss draft objections to measures (light bulbs and fridges in 2009) or vote to reject a measure (vacuum cleaners in 2013
[31](#footnote31)
). On one occasion an objection was even adopted in plenary, blocking the measure for televisions in 2009
[32](#footnote32)
.

Today, 30 Ecodesign Regulations, 17 Energy Labelling Regulations, 3 voluntary agreements and 2 tyre labelling regulations have been implemented. An overview of these measures can be found in 
[Table 63](#_Ref509854001)
.

Table 63: Overview of applicable measures

|  |  |  |
| --- | --- | --- |
| Framework legislation | | |
| 2017/1369 | Energy labelling Framework Regulation | |
| 2009/125/EC | Ecodesign Framework Directive | |
| 1222/2009/EC | European Parliament and Council Regulation on the labelling of tyres with respect to fuel efficiency and other essential parameters | |
| 30 Ecodesign implementing regulations | | |
| 1275/2008 | Standby and off mode electric power consumption | |
| 107/2009 | Simple set-top boxes | |
| 244/2009 | Non-directional household lamps (amended by 859/2009/EC) | |
| 245/2009 | Fluorescent lamps without integrated ballast, for high intensity discharge lamps and for ballasts and luminaires (amended by 347/2010/EU) | |
| 278/2009 | External power supplies | |
| 640/2009 | Electric motors (amended by regulation 4/2014/EU) | |
| 641/2009 | Circulators (amended by regulation 622/2012/EU) | |
| 642/2009 | Televisions | |
| 643/2009 | Household refrigerating appliances | |
| 1015/2010 | Household washing machines | |
| 1016/2010 | Household dishwashers | |
| 327/2011 | Fans | |
| 206/2012 | Air conditioning and comfort fans | |
| 547/2012 | Water pumps | |
| 932/2012 | Household tumble driers | |
| 1194/2012 | Directional lamps, light emitting diode (LED) lamps and related equipment | |
| 617/2013 | Computers and servers | |
| 666/2013 | Vacuum cleaners | |
| 801/2013 | Networked standby electric power consumption | |
| 813/2013 | Space heaters | |
| 814/2013 | Water heaters | |
| 66/2014 | Domestic cooking appliances (ovens, hobs and range hoods) | |
| 548/2014 | Power transformers | |
| 1253/2014 | Ventilation units | |
| 2015/1095 | Professional refigeration | |
| 2015/1188 | Solid fuel local space heaters | |
| 2015/1189 | Local space heaters | |
| 2015/1189 | Solid fuel boilers | |
| 2016/2281 | Air heating products, cooling products, high temperature process chillers and fan coil units | |
| 2016/2282 | Use of tolerances in verification procedures | |
| 17 Energy labelling supplementing regulations | | |
| 1059/2010 | Household dishwashers | |
| 1060/2010 | Household refrigerating appliances | |
| 1061/2010 | Household washing machines | |
| 1062/2010 | Televisions | |
| 626/2011 | Air conditioners | |
| 392/2012 | Household tumble driers | |
| 874/2012 | Electrical lamps and luminaires | |
| 665/2013 | Vacuum cleaners | |
| 811/2013 | Space heaters | |
| 812/2013 | Water heaters | |
| 65/2014 | Domestic cooking appliances (ovens and range hoods) | |
| 518/2014 | Internet energy labelling | |
| 1254/2014 | Domestic ventilation units | |
| 2015/1094 | Professional refrigeration | |
| 2015/1186 | Local space heaters | |
| 2015/1187 | Solid fuel boilers | |
| 2017/254 | Use of tolerances in verification procedures | |
| 3 Voluntary Agreements (Report to the EP & Council) | | |
| COM (2012) 684 | Complex set top boxes | |
| COM (2013) 23 | Imaging equipment | |
| COM(2015)178 | Game consoles | |
| 2 tyre labelling amending regulations | | |
| 228/2011 | Wet grip testing method for C1 tyres | |
| 1235/2011 | Wet grip grading of C2, C3 tyres, measurement of tyres rolling resistance and verification procedure | |
| Previous legal acts still in force | | |
| 92/42/EEC | | Hot-water boilers efficiency Council Directive (Ecodesign) |
| 96/60/EC | | Household combined washer-driers (Energy labelling) |
| 2002/40/EC | | Household electric ovens Commission Directive (Energy labelling) – will be repealed on 1/1/2015 |

MSAs, designated by the MSs, will verify the conformity of the products with the requirements laid down in the implementing measures and delegated acts. These can be done either on the product itself or by verifying the technical documentation. The rules on Union market surveillance and control of products entering the Union market are given in Regulation (EC) No 765/2008
[33](#footnote33)
. Given the principle of free movement of goods, it is imperative that MSs' market surveillance authorities cooperate with each other effectively.

  

Annex 8: Existing Policies, Legislation and Standards affecting lighting products

A number of directives and regulations affect lighting products.

1.EU ecodesign and energy labelling regulations

The current Ecodesign Regulations (Commission Regulations (EC) 244/2009, (EC) 245/2009 and (EU) 1194/2012) sets minimum energy efficiency requirements, functional requirements and information requirements for lighting products, mostly for light sources and control gears, and on a lower level for luminaires. Luminaires only have functional requirements (better said: the control gears in the luminaires need to respect those requirements). The light sources in scope of the three Regulations are electrically operated product intended to emit and/or be possibly tuned to emit light with all of the following optical characteristics that define a so-called “white light area”:

(a)chromaticity coordinates x and y in the range

0,270 < x < 0,530 and

– 2,3172 x2 + 2,3653 x – 0,2199 < y < – 2,3172 x2 + 2,3653 x – 0,1595;

(b)a luminous flux < 1000 lm per mm² of projected light-emitting surface area as defined in Annex II;

(c)a luminous flux between 60 and 82 000 lumen;

(d)a colour rendering index CRI > 0 Ra;

using incandescence, fluorescence, high-intensity discharge, light emitting diodes or their combinations as lighting technology. High-pressure sodium light sources that do not fulfil condition (a) are considered light sources for the purposes of the Regulations. The “white light area” for special purpose lamps is slightly bigger.

The current Energy labelling Regulation sets energy labelling requirements for light sources (lamps) and luminaires, but not for control gears.

Ecodesign and energy labelling regulations on components - In addition to ecodesign and energy labelling regulations on the final products, some ecodesign requirements might be applicable on the product’s components. Components that are regulated under ecodesign and/or energy labelling are the following:

·External power supplies (Ecodesign Regulation (EC) No 278/2009
[34](#footnote34)
)

·Electric motors (Ecodesign Regulation (EC) No 640/2009
[35](#footnote35)
);

·Circulators (Ecodesign Regulation (EC) No 641/2009
[36](#footnote36)
);

·Fans (Ecodesign Regulation (EU) No 327/2011
[37](#footnote37)
);

·Water pumps (Ecodesign Regulation (EU) No 547/2012
[38](#footnote38)
);

The components of lighting products are not in the scope of these regulations.

Horizontal ecodesign regulations - In addition to those requirements, some horizontal aspects of energy using products are regulated. Horizontal measures are:

·Electric power consumption standby and off mode (Ecodesign Regulation (EC) No 1275/2008
[39](#footnote39)
);

·Networked standby (Ecodesign Regulation (EU) No 801/2013
[40](#footnote40)
).

Lighting products are not in the scope of these regulations, although the new legislation proposes to include energy consumption from standby modes.

2.Other EU policies

The Low Voltage Directive
[41](#footnote41)
 regulates health and safety aspects including e.g. mechanical, chemical, noise related or ergonomic aspects. Apart from this, the directive seeks to ensure that the covered equipment benefits fully from the Single Market. The LVD covers electrical equipment operating with a voltage between 50 and 1000 V for alternating current and between 75 and 1500 V for direct current. Falling under this category, lighting products are covered by the scope of the LVD, but there is no overlapping in terms of the type of requirements.

The WEEE Directive set requirements on e.g. recovery and recycling of Waste of Electrical and Electronic Equipment to reduce the negative environmental effects resulting from the generation and management of WEEE and from resource use. The WEEE Directive applies directly to lighting products. Ecodesign implementing measures can complement the implementation of the WEEE Directive by including e.g. measures for material efficiency, thus contributing to waste reduction, instructions for correct assembly and disassembly, thus contributing to waste prevention and others.

The RoHS Directive
[42](#footnote42)
 restricts the use of six specific hazardous materials and four different phthalates found in electrical and electronic equipment (EEE). Lighting products, namely light sources when they contain mercury, are directly covered by the RoHS Directive. There is no overlapping requirement with a proposed ecodesign regulation.

The REACH Directive
[43](#footnote43)
 restricts the use of Substances of Very High Concern (SVHC) to improve protection of human health and the environment. The REACH Directive applies directly to lighting products. There is no overlapping requirement with a proposed ecodesign regulation.

The EMC Directive
[44](#footnote44)
 sets requirements for the Electro-Magnetic Compatibility performance of electrical equipment to ensure that electrical devices will function without causing or being affected by interference to or from other devices. The EMC Directive applies directly to lighting products. There is no overlapping requirement with a proposed ecodesign regulation.

The ETS sets a cap on the total amount of certain greenhouse gasses that can be emitted by installations. This cap reduces over time, so that the total emissions fall. Within this cap companies receive or buy emission allowances which they can trade with one another as needed. They can also buy a limited amount of international credits. The ETS does not directly apply to lighting products, however, it does apply to electricity production. Hence, if the electricity consumption of lighting products reduces, the electricity companies will have to trade less or the price of carbon will reduce under the cap system. Consequently, the price of electricity will drop. 

3.Non-EU policies

The Standards & Labelling database 
[www.clasponline.org](http://www.clasponline.org)
 distinguishes 280 different energy efficiency measures such as minimum efficiency requirements, comparative energy labels and endorsement labels. Countries with active energy efficiency policy tend to address lighting products. Over 50 countries have minimum energy efficiency requirements in the lighting sector.

Many countries have either introduced energy labels based on or inspired by the EU energy label
[45](#footnote45)
, the United States of America (USA) programs or a combination of both.

The International Energy Agency (IEA) Energy Efficient End-use Equipment (4E) Benchmarking programme has made a comparison of the efforts in several countries, based on a normalised kWh/a Annual Unit Energy Consumption, see 
[Figure 34](#_Ref508809694)
.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49008.jpg)

Figure 34: Average Unit Energy Consumption in selected countries and regions (Source: IEA 4E M&B, version 2014)

[Figure 34](#_Ref508809694)
 shows that the EU was still at the forefront in 2011; however, the upcoming reviews in Australia and the USA for lighting products may change this picture.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49009.jpg)

The picture above shows the around 50 countries that, as of November 2017, had adopted or were adopting minimum ecodesign requirements (MEPS) and/or energy labelling for lighting.

To safeguard competition in the EU, it is important that the EU keeps on distinguishing based on innovation and quality. Up to date requirements will enable this. In addition, the use of the standard, adapted to the EU situations, in ecodesign and energy labelling is essential for global competitiveness.

  

Annex 9: Evaluation of the Ecodesign and Energy Labelling Regulations for lighting products

In the context of the Better Regulation policy
[46](#footnote46)
, the Commission is committed to evaluate all EU activities intended which have an impact on society or the economy in a proportionate way. In the case of ecodesign and energy labelling, the two Regulations establishing the framework for the measures have been evaluated.

This annex presents the relevant findings of the evaluation of the Ecodesign and Energy Labelling legislation complemented by findings from the Review study 2015 and the impact assessment. The annex focuses on relevance, effectiveness and efficiency. As for relevance, the evaluation of the framework Regulations has shown that the objectives (increasing energy efficiency and the level of protection of the environment; providing consumers with information that allows them to choose more efficient products; and ensuring the free movement of energy-related products in the European Union) remain very much relevant.

Summary

The review of the ecodesign and energy labelling for lighting products started in 2015 and several studies were conducted for this purpose, as described in Annex 1. These studies evaluated the impact of the current legislation, as reported in this annex: they also looked at the technological and economic evolution of the sector and at stakeholders' views. Results from the studies have been used directly as input to the problem definition analysis model (see Annex 4).

The main finding from the evaluation of the impact of the current legislation is that electricity savings due to the existing requirements were expected to be 110 TWh in 2020, but according to the latest estimation they will be limited to 70 TWh. The evaluation showed that the gap in energy savings is the result of:

·Insufficient market surveillance by Member States;

·Too many parameters to verify by market surveillance, and too expensive/long verification testing required (e.g. 6000h test for lumen maintenance);

·Unclear definitions for exempted lamp types ("special purpose lamps", as defined in the current legislation), using a description of intended use rather than measurable parameters;

·Tolerances intended for use by market surveillance during verification that have been used also by manufacturers in the declaration of lamp characteristics, with the result to bring on the market products with an efficacy that is lower than the minimum required one;

·Recent appearance on the market of ‘fully-integrated luminaires’ from which the light source cannot be removed for compliance verification.

Moreover, incandescent lamps, which the ecodesign legislation phased-out from 2009, were expected to be mainly replaced by compact fluorescent lamps. However, many consumers preferred the less energy-efficient halogen lamps. Fluorescent lamps have not been adopted as expected because of (real or perceived) sub-standard performance (e.g. colour rendering and temperature, ignition time, mercury hazards).

Acronyms

AR111
   Lamp shape: Wide and flat reflector lamp, 111 mm diameter

CFL
   Compact Fluorescent Lamp (all types)

CFLi
   CFL with integrated control gear

CFLni
   CFL without integrated control gear

CMH
   MH-lamp with ceramic technology

DLS
   Directional Light Source (light concentrated in a beam, spot light)

E
   Cap-type, screw-in

E14
   Cap-type, screw with 14 mm diameter

E27
   Cap-type, screw with 27 mm diameter

FL
   Fluorescent lamp (all types)

G
   Cap-type, push-in or push-in and turn

G4
   Cap-type with two pins at 4 mm distance for low-voltage

G53
   Cap-type with two pins at 53 mm distance for low-voltage

G9
   Cap-type with two pins at 9 mm distance for mains-voltage

GLS
   Incandescent, non-halogen, filament lamp (classic light bulb)

GLS R
   GLS reflector lamp, DLS

GLS X
   GLS non-reflector lamp, NDLS

GU4
   Cap-type with two pins at 4 mm distance for low-voltage

GU5.3
   Cap-type with two pins at 5.3 mm distance for low-voltage

GU10
   Cap-type with two pins at 10 mm distance for mains-voltage

GY6.35
   Cap-type with two pins at 6.35 mm distance for low-voltage

HID
   High-Intensity Discharge lamp (all types)

HL
   Halogen lamp (all types)

HL LV C
   Halogen Low-Voltage Capsule, with G4 or GY6.35 cap, NDLS

HL LV R
   Halogen lamp, Low-Voltage, Reflector type (mirrored), DLS:

   e.g. MR11-GU4, MR16-GU5.3, AR111-G53

HL MV C
   Halogen Mains-Voltage Capsule, with G9 cap, NDLS

HL MV E
   Halogen lamp, Mains-Voltage, most with E-cap, NDLS

HL MV L
   Halogen lamp, linear, double-ended R7s cap, NDLS

HL MV X
   Halogen lamp, Mains-Voltage, Reflector type (mirrored), DLS:

   e.g. MR16-GU10, R- and PAR-lamps with E14 and E27 caps

HPM
   High-Pressure Mercury lamp (type of HID)

HPS
   High-Pressure Sodium lamp (type of HID)

LED
   Light-Emitting Diode light source

LFL
   Linear Fluorescent Lamp (all types)

LFL T5
   LFL with diameter of 16 mm (5/8 inch), 14-80W, incl. circular

LFL T8
   LFL with diameter of 26 mm (8/8 inch) (all types)

LFL T8t
   LFL T8 with tri-phosphor technology

LFL T8h
   LFL T8 with halo-phosphor technology

LFL T12
   LFL with diameter of 38 mm (12/8 inch)

LFL X
   LFL other than T12, T8 and T5 (incl. e.g. T9, special FL, U-shaped, T5 ≤ 13 W)

LV
   Low-Voltage (less than 230 V, typically 12 or 24 V)

MH
   Metal-Halide lamp (type of HID)(all types)

MR11, MR16
   Lamp shape: Small reflector lamps (DLS)

MV
   Mains-Voltage (230 V)

NDLS
   Non-Directional Light Source (light not concentrated in a beam)

PAR
   Lamp shape: Parabolic reflector lamp (DLS)

QMH
   MH-lamp with quartz technology

R
   Lamp shape: Reflector lamp (DLS)

R7s
   Cap-type, with thick pin at each extremity of a tube-shaped lamp

1.BAU 2008 scenario, assumptions

The BAU scenario for the situation without the Ecodesign and Energy Labelling measures taken in 2009 and 2012 was developed during the 2009 and 2012 Impact Assessments and is reported in the Ecodesign Impact Accounting (EIA, version of December 2016). This scenario was based on data available in 2008 and before, and used an analysis model that was far less detailed than the current MELISA model. Hence, the existing BAU2008 scenario for lighting (without effects of existing regulations) is not compatible with the current BAU (indicated as BAU2015 below) and ECO scenarios from MELISA.

In order to enable a better insight in the impacts that current regulations had, a BAU2008 scenario has been developed, using the data and insights now available, and using the same analysis method used in MELISA. A separate, dedicated MELISA version was developed for the BAU2008 scenario, starting from the current BAU scenario and reasoning backwards to what would have happened if the existing lighting regulations would not have been introduced.

The following assumptions have been made to convert the current BAU scenario (BAU2015, with effects of existing regulations) to a BAU2008 scenario
[47](#footnote47)
 (without effects of existing regulations):

LFL T12:

Sales in BAU2015 are decreasing and shifting to LFL T8t because of T12 phase-out due to CR 245/2009. For BAU2008 (without regulation) this phase-out has been slightly slowed down, but minor impact on total because T12 figures are already low.

LFL T8h:

Sales in BAU2015 are decreasing and shifting to LFL T8t because of T8h phase-out due to CR 245/2009. For BAU2008 (without regulation) this phase-out has been slowed down.

LFL T5:

Sales for years 2009-2013: for BAU2008 without CR 245/2009 assume that shift of sales from T12 and T8 to T5 would have been slower → lower T5 sales.

CG-efficiency increase after 2008 partly induced by CR 245/2009: reduce increase for BAU2008.

LS-efficiency increase after 2008 is induced by CR 245/2009: maintain 2008 values for BAU2008.

For LFL T5 non-residential maintain lifetime increase and lumen increase from LightingEurope input.

For T5 the shift towards LED in BAU2015 was already slow: maintain same scenario for BAU2008

LFL T8t:

Sales for years 2009-2013: adapted in function of changes in sales for T12, T8h and T5, such that the total stock for all LFL-applications (incl. LED replacements) remains the same as before.

CG-efficiency increase after 2008 partly induced by CR 245/2009: reduce increase for BAU2008

LS-efficiency increase after 2008 partly induced by CR 245/2009: reduce increase for BAU2008

For LFL T8t non-residential maintain lifetime increase and lumen increase from LightingEurope input.

For T8t the shift towards LED in BAU2015 was already slow, but it has been further slowed down for BAU2008

LFLX:

Impact of this group on totals is low and it is a strange mixed group with few data available: do not change sales.

CG-efficiency increase after 2008 partly induced by CR 245/2009: reduce increase for BAU2008

For LFL X the shift towards LED in BAU2015 was already slow, but it has been further slowed down for BAU2008.

All HID types:

BAU2015 assumed a CG efficiency increase due to 245/2009. This increase has been reduced for the BAU2008 scenario.

HPM:

CR 245/2009 phases out HPM from 2015. In BAU2015 these are substituted by a combination of HPS, MH and LED and HPM disappear completely from 2020

Without CR, it is assumed that HPM phase-out would have occurred anyway due to measures on mercury (RoHS), so shift in sales towards HPS and MH has not been changed up to 2014.

Later years: reduced the speed of shift towards LED, implying that more HPM shift to HPS and MH.

In BAU2008, HPM anyway disappear completely from stock in 2020, just as in BAU2015.

HPS:

Increase in lifetime and lumens agreed with LE has been maintained for BAU2008

MELISA included a LS efficiency increase from 2010. This is assumed to be partly induced by CR 245/2009 and the increase has been reduced for BAU2008

Removed LED replacements before 2014 and added these sales to HPS

Speed of substitution by LEDs was already low, but has been further reduced.

MH:

Increase in lifetime and lumens agreed with LE has been maintained for BAU2008

MELISA included a LS efficiency increase from 2010. This is assumed to be partly induced by CR 245/2009 and the increase has been reduced for BAU2008

Removed LED replacements before 2014 and added these sales to MH

Speed of substitution by LEDs was already low, but has been further reduced.

Substitution of HPS by MH also slightly adapted

CFLi:

In absence of CR 244/2009 there is no phase-out of GLS, and consequently the quantities of CFLi replacing GLS should be lower in BAU2008 than in BAU2015. Until 2005 maintain sales as they are (220 mln in 2005). From 2007-2013 maintain first increasing, then declining trend, but with much lower peak (350 mln instead of 506 mln). After 2013 continue to apply normal MELISA calculation but add a share of sales replacing GLS.

Defined new rate of substitution by LEDs (in early years after 2014 the rate has been ‘tailored’ to avoid a return of the 2010 CFLi sales peak around 2020. In later years rate stabilizes on 70% of potential CFLi sales being filled in by LED).

CFLi efficiency was not affected by existing regulations, so BAU2015 values maintained.

CFLni:

BAU2015 implemented an efficiency increase for both light sources and control gears from 2009. This increase was induced by CR 245/2009 and has been removed in BAU2008: kept efficiencies on 2009 level.

Assumed that CR 245/2009 did not influence CFLni sales until 2014. Hence kept sales until 2014 same as in BAU2015.

Defined new rate of substitution by LEDs (very low in early years after 2014, then stabilizing on 70%).

GLS Storage:

MELISA considers a ‘GLS Storage effect’. This effect takes into account that after the phase-out of NDLS GLS, residential users anyway continue to install such lamps from the stocks they had in house, for a limited time, until stocks are exhausted. This temporarily slows down the shift to HL, CFLi and LED. Without CR 244/2009, so without the GLS phase-out, there would not have been such an effect, so for BAU2008, all GLS storage data have been set to zero (same was done in EIA BAU2008).

GLS X (NDLS): 

BAU 2008 implies no forced phase-out of GLS. Until 2007 maintain sales as they are (1356 mln in 2007). From 2007-2013 maintain declining trend, but much less fast than before (down to 1140 mln in 2013 instead of 123 mln). After 2013 impose shift to HL/CFLi and scenario shift to LED in such a way that GLS sales in a year decrease by approximately 10% with respect to previous year. The shift to HL/CFLi decreases from around 100 mln in 2014 to 0 in 2025.

Define new rate of substitution by LEDs (very low in early years after 2014, then stabilizing on 22% of potential GLS sales).

For BAU2008 maintained MELISA lm, W, and lm/W (assumed there was no efficiency increase for GLS due to CR 244/2009; only a phase-out).

GLS R (DLS):

Situation slightly different from GLS (NDLS) due to later entry into force of CR 1194/2012. Impact on of GLS R (DLS) on totals is small.

Anyway followed more or less the same philosophy as for GLS NDLS

For BAU2008 maintained MELISA lm, W, and lm/W (also because this reflects difference between total lumen and lumen in cone (capacity would change considerably).

HL Storage:

MELISA considers a ‘HL Storage effect’. This effect takes into account that after the phase-out of NDLS HL, residential users anyway continue to install such lamps from the stocks they had in house, for a limited time, until stocks are exhausted. This temporarily slows down the shift to LED. Without CR 244/2009, so without the HL phase-out, there would not have been such an effect, so for BAU2008, all HL storage data have been set to zero (same was done in EIA BAU2008).

HL MV E (NDLS):

The absence of CR 244/2009 implies no forced phase-out of GLS, so initially HL sales substituting GLS should be lower in BAU2008 than in BAU2015. Until 2007 maintain sales as they are. For 2007-2013 (considering changes made for CFLi, GLS and HL Storage) adapt sales in such a way that the total NDLS stock is maintained on the same level as in BAU2015. After 2013 apply standard MELISA calculation of sales, but adding a contribution for GLS that have to be substituted and are not yet substituted by CFLi, and adding also a contribution that takes into account the 'sales' removed from HL Storage.

Defined new rate of substitution by LEDs (very low in early years after 2014, then stabilizing on 40% of potential HL MV E sales).

MELISA assumed an increase in efficiency to enable lamps to meet the 244/2009 requirements for 2012-2018. The BAU2008 should not consider this, so pre-2012 efficiency has been maintained also in future years. Note that lumens have not been changed (to avoid changes in total load), so that lower efficiency implies higher power.

HL LV C:

CR 244/2009 imposes MEPS that have been taken into account in BAU2015 by increasing efficiencies from 2013 onwards. In BAU2008 such an efficiency increase would not be required, so assume it would not occur: maintain pre-2013 efficiencies. No change in lumens.

Assume that sales in BAU2008 are the same as in BAU2015, but in absence of any regulation stimulating LED development in general, assume a slower shift to LEDs (same as for HL MV E (NDLS).

HL MV C:

CR 244/2009 imposes MEPS that have been taken into account in BAU2015 by increasing efficiencies from 2011 onwards (G9 cap exempted from stage 6 but not from earlier stages). In BAU2008 such an efficiency increase would not be required, so assume it would not occur: maintain pre-2011 efficiencies. No change in lumens.

Assume that sales in BAU2008 are the same as in BAU2015, but in absence of any regulation stimulating LED development in general, assume a slower shift to LEDs (same as for HL MV E (NDLS).

HL MV L:

CR 244/2009 imposes MEPS that have been taken into account in BAU2015 by increasing efficiencies from 2010 onwards (R7s cap exempted from stage 6 but not from earlier stages). In BAU2008 such an efficiency increase would not be required, so assume it would not occur: maintain pre-2010 efficiencies. No change in lumens.

Assume that sales in BAU2008 are the same as in BAU2015, but in absence of any regulation stimulating LED development in general, assume a slower shift to LEDs (same as for HL MV E (NDLS).

HL LV R and HL MV X (DLS):

Adapted sales in function of changes for GLS R, in such a way that total DLS stock remains the same.

In absence of any regulation stimulating LED development in general, assume a slower shift to LEDs (same as for HL MV E (NDLS).

For HL LV R in BAU2015 efficiencies were increased from 2016, but this increase has been removed for BAU2008 (maintaining same lumens).

As regards LED efficacy and price projections, it is difficult to say how these would have changed with respect to the projections presented for the current BAU (see Annex 5 Section 2.3 on LED efficacy and price projections) if no measures would have been taken in 2009-2012, but it is reasonable to assume that LED development would have somewhat slowed down without these measures. In BAU2008 the same LED projection curves are used as in the current BAU but with a two year delay.

  

2.Impact of current regulations: BAU2008 vs. BAU2015, Sales

The BAU2015 scenario includes the effects of the existing regulations and consequently has the same meaning as an ECO2008 scenario. Comparing the BAU2008 scenario to the BAU2015=ECO2008 scenario thus provides the impact of the existing regulations.

In the BAU2008 scenario, sales for GLS decrease much slower than in BAU2015. Consequently, there are also less sales of HL and CFLi. In BAU2008, on average, light sources have a lower lifetime, requiring more frequent substitution, and consequently sales quantities are much higher than in BAU2015.

BAU2008

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49010.jpg)

BAU2015

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49011.jpg)

Figure 35 Total EU-28 Sales, in million units, for BAU2008 and BAU2015 scenarios.

3.Impact of current regulations: BAU2008 vs. BAU2015, Stock

The total stock of installed light sources is identical in the BAU2008 and BAU2015 scenarios, but the composition of the stock is different. In BAU2008, more GLS, HL and CFLi remain in the stock while the share of LEDs is much smaller.

BAU2008

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49012.jpg)

BAU2015

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49013.jpg)

Figure 36 Total EU-28 Stock, in million units, for BAU2008 and BAU2015 scenarios.

  

4.Impact of current regulations: BAU2008 vs. BAU2015, Electricity

In 2015, existing lighting regulations saved 41 TWh/a of electricity. This is expected to increase to 93 TWh/a in 2020. In later years annual savings would decrease, reaching 71 TWh/a in 2030.

BAU2008

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49014.jpg)

BAU2015

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49015.jpg)

|  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| TWh | | 2005 | 2010 | 2015 | 2020 | 2025 | 2030 | Cumulative 2005-2030 |
| BAU 2008 | Electricity | 309 | 346 | 377 | 413 | 403 | 370 | 9752 |
| BAU 2015 | saving |  | -18.1 | -40.9 | -92.9 | -90.2 | -71.2 | -1415 |

Figure 37 Total EU-28 Electricity consumption, in TWh/a, for BAU2008 and BAU2015 scenarios.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49016.jpg)

Figure 38 Comparison of the total EU-28 electricity consumption for lighting, in TWh/a, for the BAU2008 and BAU2015 scenarios. The electricity saving of the BAU2015 scenario vs. the BAU2008 scenario is the impact of the existing lighting regulations.

In 2015-2025, the major savings due to existing lighting regulations have been or will be obtained on the NDLS (household) applications. In 2015, 26 of the in total 41 TWh electricity savings (63%) were obtained on NDLS. In 2020 this is expected to be 53 on 93 TWh (57%). Second largest savings are obtained on DLS (household) applications (16 on 93 TWh, 17%, in 2020). Effects of the current regulations on light sources used mainly in the tertiary sector and in industry (FL, HID, CFLni) appear mainly from 2020 onwards.

  

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 64 Savings on Electricity Consumption for Lighting, of the BAU2015 scenario vs. the BAU2008 scenario, in TWh/a or TWh cumulative. This is the impact of the existing lighting regulations. Positive value = saving; Negative value = additional electricity | | | | | | |
| TWh electricity saving  BAU2015 vs. BAU2008 | 2010 | 2015 | 2020 | 2025 | 2030 | cumulative  2005-2030 |
| Total EU-28, all sectors | 18 | 41 | 93 | 90 | 71 | 1415 |
| total Residential (RES) | 12 | 22 | 54 | 43 | 24 | 717 |
| total Non-Residential (NRES) | 6 | 18 | 39 | 48 | 48 | 698 |
| total Classic Technology | 18 | 54 | 123 | 126 | 104 | 1911 |
| total LED | 0 | -13 | -30 | -36 | -33 | -496 |
|  |  |  |  |  |  |  |
| LFL T8t | -5 | -18 | 2 | 16 | 24 | 43 |
| LFL T5 (13-80 W) | 0 | 0 | 6 | 8 | 8 | 93 |
| other LFL | 6 | 24 | 8 | 1 | 1 | 207 |
| LED in former LFL-applications | 0 | -1 | -4 | -7 | -9 | -87 |
| Total LFL-applications | 1 | 5 | 12 | 19 | 24 | 256 |
|  |  |  |  |  |  |  |
| HPM | 0 | 0 | 0 | 0 | 0 | 1 |
| HPS | 0 | 6 | 10 | 12 | 13 | 188 |
| MH | 1 | 7 | 13 | 13 | 10 | 205 |
| LED in former HID-applications | 0 | -10 | -14 | -13 | -10 | -211 |
| Total HID-applications | 1 | 4 | 10 | 13 | 13 | 184 |
|  |  |  |  |  |  |  |
| CFLni | 0 | 1 | 3 | 4 | 4 | 54 |
| LED in former CFLni-applications | 0 | 0 | -1 | -2 | -1 | -18 |
| Total CFLni-applications | 0 | 1 | 2 | 3 | 3 | 36 |
|  |  |  |  |  |  |  |
| HL LV R (MR/AR) (GU4,GU5.3,G53) | 0 | 1 | 5 | 6 | 5 | 72 |
| HL MV (DLS) (GU10 or E-cap) | -3 | 1 | 10 | 7 | 4 | 96 |
| GLS (DLS) | -3 | 4 | 3 | 2 | 1 | 57 |
| LED in DLS-applications | 0 | -1 | -3 | -2 | -2 | -38 |
| Total DLS-applications | -6 | 5 | 16 | 12 | 8 | 186 |
|  |  |  |  |  |  |  |
| CFLi | -3 | -4 | 1 | 8 | 9 | 37 |
| HL MV (NDLS, E-cap) | -2 | -10 | 16 | 19 | 9 | 127 |
| GLS (NDLS) | 26 | 36 | 35 | 21 | 12 | 595 |
| HL LV Capsule (G4, GY6.35) | 0 | 0 | 1 | 2 | 1 | 20 |
| HL MV Capsule (G9) | 0 | 1 | 2 | 2 | 1 | 27 |
| HL MV Linear (R7s) | 1 | 5 | 6 | 5 | 2 | 90 |
| LED in NDLS-applications | 0 | -1 | -9 | -12 | -10 | -142 |
| Total NDLS-applications | 21 | 26 | 53 | 44 | 24 | 754 |

  

5.Impact of current regulations: BAU2008 vs. BAU2015, GHG emissions

In 2015, existing lighting regulations reduced GHG emission due to electricity consumption for lighting by 16 MtCO2eq/a. This is expected to increase to 35 MtCO2eq/a in 2020. In later years annual reduction would decrease, reaching 24 MtCO2eq/a in 2030.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49017.jpg)

|  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| MtCO2eq | | 2005 | 2010 | 2015 | 2020 | 2025 | 2030 | Cumulative 2005-2030 |
| BAU 2008 | GHG emission | 130 | 142 | 149 | 157 | 145 | 126 | 3738 |
| BAU 2015 | saving |  | -7 | -16 | -35 | -32 | -24 | -525 |

Figure 39 Comparison of the total EU-28 GHG emissions due to lighting, in MtCO2eq/a, for the BAU2008 and BAU2015 scenarios. The emission reduction of the BAU2015 scenario vs. the BAU2008 scenario is the impact of the existing lighting regulations.

  

6.Impact of current regulations: BAU2008 vs. BAU2015, Total user expense

In 2015, the existing regulations made EU-28 users save 3.1 billion EUR/a on their expenses for lighting. By 2020 this is projected to be 19.6 billion EUR/a.

BAU2008

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49018.jpg)

BAU2015

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49019.jpg)

|  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- |
| bn euros | | 2005 | 2010 | 2015 | 2020 | 2025 | 2030 | Cumulative 2005-2030 |
| BAU 2008 | Total User Expense | 49 | 62 | 73 | 90 | 97 | 103 | 2078 |
| BAU 2015 | saving |  | -2.1 | -3.1 | -19.6 | -24.2 | -20.5 | -308 |

Figure 40 Total EU-28 User Expense for lighting, in bn euros, for BAU2008 and BAU2015 scenarios.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49020.jpg)

Figure 41 Comparison of the EU-28 total user expense for lighting, in billion EUR per year, for the BAU2008 and BAU2015 scenarios. The savings of the BAU2015 scenario vs. the BAU2008 scenario are the impact of the existing lighting regulations.

In 2015-2025, the major savings due to existing lighting regulations have been or will be obtained on the NDLS (household) applications. In 2020, 12 of the in total EUR 20 billion expense savings (60%) are obtained on NDLS. Second largest savings are obtained on DLS (household) applications (4 on 20 TWh, 20%, in 2020). Effects of the current regulations on light sources used mainly in the tertiary sector and in industry (FL, HID, CFLni) appear mainly from 2020 onwards.

|  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- |
| Table 65 Savings on Total User Expense for Lighting, of the BAU2015 scenario vs. the BAU2008 scenario, in bn EUR/a or bn EUR cumulative. This is the impact of the existing lighting regulations. Positive value = saving; Negative value = additional expense | | | | | | |
| TWh electricity saving  BAU2015 vs. BAU2008 | 2010 | 2015 | 2020 | 2025 | 2030 | cumulative  2005-2030 |
| Total EU-28, all sectors | 2 | 3 | 20 | 24 | 20 | 308 |
| total Residential (RES) | 2 | 2 | 14 | 15 | 10 | 194 |
| total Non-Residential (NRES) | 1 | 1 | 6 | 9 | 10 | 114 |
| total Classic Technology | 2 | 12 | 30 | 33 | 30 | 471 |
| total LED | 71 | -9 | -10 | -9 | -10 | -163 |
|  |  |  |  |  |  |  |
| LFL T8t | -1.2 | -2.4 | 0.3 | 3.0 | 5.3 | 12.1 |
| LFL T5 (13-80 W) | -0.1 | 0.1 | 1.0 | 1.4 | 1.8 | 16.9 |
| other LFL | 1.4 | 4.0 | 1.4 | 0.3 | 0.3 | 37.4 |
| LED in former LFL-applications | 0.0 | -0.6 | -0.8 | -1.4 | -2.6 | -21.7 |
| Total LFL-applications | 0 | 1 | 2 | 3 | 5 | 45 |
|  |  |  |  |  |  |  |
| HPM | 0.0 | 0.0 | 0.0 | 0.0 | 0.0 | 0.1 |
| HPS | 0.0 | 0.9 | 1.5 | 2.2 | 2.7 | 30.9 |
| MH | 0.1 | 1.1 | 2.1 | 2.5 | 2.3 | 36.3 |
| LED in former HID-applications | 0.0 | -2.8 | -2.1 | -2.5 | -2.4 | -44.5 |
| Total HID-applications | 0 | -1 | 2 | 2 | 3 | 23 |
|  |  |  |  |  |  |  |
| CFLni | 0.0 | 0.3 | 0.9 | 1.5 | 1.5 | 18.4 |
| LED in former CFLni-applications | 0.0 | -0.3 | -0.7 | -0.8 | -0.8 | -11.2 |
| Total CFLni-applications | 0 | 0 | 0 | 1 | 1 | 7 |
|  |  |  |  |  |  |  |
| HL LV R (MR/AR) (GU4,GU5.3,G53) | 0.0 | 0.3 | 1.2 | 1.6 | 1.7 | 19.9 |
| HL MV (DLS) (GU10 or E-cap) | -0.4 | 0.4 | 3.2 | 2.5 | 1.5 | 33.0 |
| GLS (DLS) | 0.3 | 0.9 | 0.9 | 0.6 | 0.4 | 14.5 |
| LED in DLS-applications | -0.2 | -1.3 | -0.9 | -0.6 | -0.7 | -17.4 |
| Total DLS-applications | 0 | 0 | 4 | 4 | 3 | 50 |
|  |  |  |  |  |  |  |
| CFLi | -1.4 | -0.5 | 1.3 | 3.1 | 3.7 | 21.6 |
| HL MV (NDLS, E-cap) | -0.8 | -2.7 | 4.6 | 5.8 | 3.4 | 44.3 |
| GLS (NDLS) | 4.3 | 8.3 | 8.9 | 6.3 | 4.4 | 150.6 |
| HL LV Capsule (G4, GY6.35) | 0.0 | 0.1 | 0.3 | 0.5 | 0.4 | 5.5 |
| HL MV Capsule (G9) | 0.0 | 0.2 | 0.5 | 0.7 | 0.5 | 8.2 |
| HL MV Linear (R7s) | 0.1 | 0.9 | 1.5 | 1.3 | 0.6 | 21.0 |
| LED in NDLS-applications | 0.0 | -3.7 | -5.5 | -3.6 | -3.4 | -67.7 |
| Total NDLS-applications | 2 | 3 | 12 | 14 | 10 | 183 |

7.Residential vs. non-residential 

Without any measures (BAU2008) residential electricity consumption for lighting in 2020 would have been 103 TWh/a. Due to the existing measures (BAU2015) this is expected to be only 49 TWh/a, a saving of 54 TWh/a (see also Table 40 in Annex 4), i.e. more than 50% saving. This spectacular saving is possible because the residential sector predominantly used incandescent (GLS) lamps with efficacy around 10 lm/W or lower. The replacement lamps have efficacies that are 1.5-2 times higher (halogen), 5 times higher (CFLi) or 10 times higher (LED).

Without any measures (BAU2008) non-residential electricity consumption for lighting in 2020 would have been 310 TWh/a. Due to the existing measures (BAU2015) this is expected to be only 271 TWh/a, a saving of 39 TWh/a (see also Table 40 in Annex 4), i.e. 13% saving. Hence, notwithstanding the much higher electricity consumption in the non-residential sector, savings due to existing regulation have been lower than in the residential sector. This is mainly due to the fact that the non-residential sector already used more efficient light sources than the residential sector. Passing from the old LFL T12 and T8 halo-phosphor to LFL T8 tri-phosphor and T5, passing from mercury lamps (HPM) to other HID lamps (HPS, MH), and replacing electromagnetic control gear by more efficient electronic control gear did increase efficiency, but starting on a higher efficiency level, this increase could not be close to a factor 2 as in the residential sector. The relatively small savings in the non-residential sector do not imply that existing measures were too weak: they did the maximum that was possible when measures were taken (2008-2009).

As a result, in 2020 it is expected that 271 of 320 TWh (85%) of EU lighting electricity is consumed in the non-residential sector, and 121 of these 271 TWh (45%) are consumed by LFL T8. For these LFL T8, LED tube replacements are available that are close to two times more efficient, and hence the main electricity savings opportunity for new measures lies there. The remaining 150 TWh in the non-residential sector is mainly consumed by LFL T5, HID and CFLni, for which replacement by LED is not yet possible / convenient.

  

Annex 10: Energy efficiency formula

ECODESIGN

1. Proposal

ENERGY EFFICIENCY REQUIREMENTS for LIGHT SOURCES

The declared power consumption of a light source at full-load Pon shall not exceed the maximum allowed power Ponmax (in W), defined in function of the declared useful luminous flux Φuse (in lm) and the declared colour rendering index CRI (in Ra) as follows:

Ponmax = C \* (L + Φuse / (F\*η)) \* R

Where:

The values for threshold efficacy (η in lm/W) and end loss factor (L in W) are specified in Table 1, depending on the light source type.

Basic values for correction factor (C) depending on light source type, and additions to C for special light source features are specified in Table 2.

Efficacy factor (F) is:

1.00 for non-directional light sources (NDLS, using total flux)

0.85 for directional light sources (DLS, using flux in a cone)

CRI factor (R) is:

0.65
   
   
   for CRI ≤ 25

(CRI+80)/160
   
   for CRI > 25

Table A: Threshold efficacy (η) and end loss factor (L)

|  |  |  |
| --- | --- | --- |
| Light source description | η | L |
|  | [lm/W] | [W] |
| LFL T5-HE | 98,8 | 1,9 |
| LFL T5-HO, 4000≤Φ≤5000 lm | 83 | 1,9 |
| LFL T5-HO, other lm output | 79 | 1,9 |
| FL T5 circular | 79 | 1,9 |
| FL T8 other than LFL 2-, 4- and 5-foot  (incl. FL T8 U-shaped) | 89,7 | 4,5 |
| FL using magnetic induction, any length/flux | 70,2 | 2,3 |
| CFLni | 70,2 | 2,3 |
| FL T9 circular | 71,5 | 6,2 |
| HPS single-ended | 88 | 50 |
| HPS double-ended | 78 | 47,7 |
| MH ≤ 405 W single-ended | 84,5 | 7,7 |
| MH > 405 W single-ended | 79,3 | 12,3 |
| MH ceramic double-ended | 84,5 | 7,7 |
| MH quartz double-ended | 79,3 | 12,3 |
| Organic light-emitting diode (OLED) | 65 | 1,5 |
| HL R7s ≤ 2700 lm | 26 | 13 |
| Other light sources in scope not mentioned above | 120 | 1,5\* |

\* For connected light sources (CLS) a factor L=2.0 shall be applied.

   
   Table B: Correction factor C depending on light source characteristics

|  |  |
| --- | --- |
| Light source type | Basic C value |
| Non-directional (NDLS) not operating on mains (NMLS) | 1 |
| Non-directional (NDLS) operating on mains (MLS) | 1,08 |
| Directional (DLS) not operating on mains (NMLS) | 1,15 |
| Directional (DLS) operating on mains (MLS) | 1,23 |
|  |  |
| Special light source feature | Bonus on C |
| FL or HID with Tc >5000 K | +0,1 |
| FL with CRI > 90 Ra | +0,1 |
| HID with second envelope | +0,1 |
| MH NDLS >405 W with non-clear envelope | +0,1 |
| DLS with anti-glare shield | +0,2 |
| Colour-tuneable light source (CTLS) | +0,1 |

Where applicable, bonuses on correction factor C are cumulative.

‘Threshold efficacy’ and ‘end loss factor’ are not light source parameters, but constants to be used in the maximum power formula.

The ‘threshold efficacy’ is not the minimum efficacy that the light source has to meet. This minimum required efficacy is lower than the ‘threshold efficacy’ and can be derived by dividing the useful luminous flux (lm) by the maximum allowed power (W) resulting from the formula.

Originally, the ‘end loss factor’ reflected a certain minimum power that would always be required, regardless of the amount of luminous flux emitted. In the course of the development of the maximum power formula, this original meaning has largely been lost. The ‘end loss factor’ is now just a constant in the formula that has been used, where applicable, to tune the new efficacy requirements such that they correspond closely to the existing requirements. The main effect of the ‘end loss factor’ is that light sources emitting a high flux are required to have a higher efficacy. If the ‘end loss factor’ would be set to zero, the required efficacy would be the same for all fluxes.

As an illustration, the required minimum efficacy for ‘Other light sources’ in Table A (including LEDs) is shown in the graph below. The curves give the minimum required efficacy in lm/W in function of the useful luminous flux, for =120 lm/W, L=1.5, CRI=80, no special features. The four curves are for non-directional (NDLS) and directional light sources (DLS), requiring an external control gear to operate on the mains power supply, or with integrated control gear (operating directly on the mains power supply). For light sources with CRI > 80, with anti-glare shield, with network connection, or colour tuneable, required efficacies are lower.

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49021.jpg)

 

The standby power of a light source Psb shall not exceed 0.5 W. The networked standby power of a connected light source Pnet shall not exceed 0.5 W

ENERGY EFFICIENCY REQUIREMENTS for CONTROL GEARS

The minimum energy efficiency requirements shall apply for separate control gear operating at full-load:

Table C: Minimum efficiency for separate control gear at full-load

|  |  |
| --- | --- |
| Declared output power of the control gear (Pcg) or declared power of the light source (Pls) in W, as applicable | Minimum efficiency |
| Control gear for HL light sources |  |
| all wattages Pcg | 0,91 |
| Control gear for FL light sources |  |
| Pls ≤ 5 | 0,71 |
| 5 < Pls ≤ 100 | Pls/(2\*√(Pls /36)+38/36\* Pls+1) |
| 100 < Pls | 0,91 |
| Control gear for HID light sources |  |
| Pls ≤ 30 | 0,78 |
| 30 < Pls ≤ 75 | 0,85 |
| 75 < Pls ≤ 105 | 0,87 |
| 105 < Pls ≤ 405 | 0,90 |
| 405 < Pls | 0,92 |
| Control gear for LED or OLED light sources |  |
| Pcg ≤ 10 | 0,70 |
| 10 < Pcg ≤ 25 | 0,75 |
| 25 < Pcg ≤ 50 | 0,83 |
| 50 < Pcg ≤ 100 | 0,86 |
| 100 < Pcg ≤ 300 | 0,88 |
| 300 < Pcg | 0,90 |

The no-load power of a separate control gear Pno shall not exceed 0.5 W. The standby power of a separate control gear Psb shall not exceed 0.5 W.

2. Current regulations

See:

[Commission Regulation (EC) No 244/2009 of 18 March 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for non-directional household lamps](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523267684326&uri=CELEX:32009R0244)
, OJ L76/3, 24.3.2009 and amendments Commission Regulations (EC) No 859/2009 and (EU) 2015/1428;
   

[Commission Regulation (EC) No 245/2009 of 18 March 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for fluorescent lamps without integrated ballast, for high intensity discharge lamps, and for ballasts and luminaires able to operate such lamps](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523267929129&uri=CELEX:32009R0245)
, OJ L76/17, 24.3.2009 and amendments Commission Regulations (EC) No 347/2010 and (EU) 2015/1428;

[Commission Regulation (EU) No 1194/2012 of 12 December 2012 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for directional lamps, light emitting diode lamps and related equipment](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1523268097398&uri=CELEX:32012R1194)
, OJ L342/1, 14.12.2012 and amendment Commission Regulation (EU) 2015/1428 (ecodesign regulations).

ENERGY LABELLING

1. Proposal

The energy efficiency class of light sources shall be determined on the basis of the efficacy values expressed in total mains efficacy TM, which is defined as the total initial luminous flux (in lm) divided by mains power input (in W) – (lm/W).

The total mains efficacy TM is calculated by dividing the declared useful luminous flux use (expressed in lm) by the declared on-mode power consumption Pon (expressed in W) and multiplying by the applicable factor FTM , i.e.:

TM = (use / Pon) \* FTM (lm/W).

|  |  |
| --- | --- |
| Factors FTM to be used for determination of TM = (use / Pon) \* FTM (lm/W) | |
| Light source type | Factor FTM |
| Non-directional mains light source (NDLS, MLS) | 1.000 |
| Non-directional non-mains light source (NDLS, NMLS) | 0.926 |
| Directional mains light source (DLS, MLS) | 1.176 |
| Directional non-mains light source (DLS, NMLS) | 1.089 |

2. Current regulation

For the calculation of the energy efficiency index (EEI) of a model, its power corrected for any control gear losses is compared with its reference power. The reference power is obtained from the useful luminous flux, which is the total flux for non-directional lamps, and the flux in a 90° or 120° cone for directional lamps.

The EEI is calculated as follows and rounded to two decimal places:

EEI = Pcor/Pref 

where:

Pcor is the rated power (Prated) for models without external control gear and the rated power (Prated) corrected for models with external control gear. The rated power of the lamps is measured at their nominal input voltage.

Power correction if the model requires external control gear 

|  |  |
| --- | --- |
| Scope of the correction | Power corrected for control gear losses (Pcor) |
| Lamps operating on external halogen lamp control gear | Prated × 1,06 |
| Lamps operating on external LED lamp control gear | Prated × 1,10 |
| Fluorescent lamps of 16 mm diameter (T5 lamps) and 4-pin single capped fluorescent lamps operating on external fluorescent lamp control gear | Prated × 1,10 |
| Other lamps operating on external fluorescent lamp control gear |  |
| Lamps operating on external high-intensity discharge lamp control gear | Prated × 1,10 |
| Lamps operating on external low pressure sodium lamp control gear | Prated × 1,15 |

Pref is the reference power obtained from the useful luminous flux of the model (Φuse) by the following formulae:

|  |
| --- |
| For models with Φuse < 1 300 lumen: Pref = 0,88√Φuse + 0,049Φuse |

|  |
| --- |
| For models with Φuse ≥ 1 300 lumen: Pref = 0,07341Φuse |

Definition of the useful luminous flux 

|  |  |
| --- | --- |
| Model | Useful luminous flux (Φuse) |
| Non-directional lamps | Total rated luminous flux (Φ) |
| Directional lamps with a beam angle ≥ 90° other than filament lamps and carrying a textual or graphical warning on their packaging that they are not suitable for accent lighting | Rated luminous flux in a 120° cone (Φ120°) |
| Other directional lamps | Rated luminous flux in a 90° cone (Φ90°) |

The weighted energy consumption (Ec ) is calculated in kWh/1 000 h as follows and is rounded to two decimal places:

![](./../../../resource.html?uri=IMMC:SWD%282019%29357.ENG.xhtml.SWD_282019_29357_ENG_xhtml_49023.jpg)

Where Pcor is the power corrected for any control gear losses.

  

Annex 11: Exemptions in Ecodesign

Aim of this Annex

The aim of this Annex is to compare the exemptions in the current ecodesign legislation for lighting products with the exemptions proposed in the options of this impact assessment for a reviewed ecodesign regulation (Option 3 ECOEL2021 and Option 4 ECOEL2tiers).

The table at the end of this annex lists the exemptions for each of the three regulations (Commission Regulations (EC) No 244/2009, (EC) No 245/2009 and (EU) No 1194/2012) and presents their status in the proposed review. In the table, the exemptions proposed in the review are split as follows in comparison to the current regulations:

-what remains exempted, divided in what is explicitly exempted and what naturally falls out-of-scope;

-what is not exempted, divided in what remains not exempted and what is no longer exempted.

Another column lists the exemptions for which there is ambiguity in the existing regulations and that the proposed review clarifies.

The last column aims to quantify the variation in energy savings following the change in the ecodesign proposal. Numbers may appear limited, but it should be kept in mind that the savings only relate to the variation from that specific use of the light source (which should be only used as a Special Purpose Lamp, according to the current regulations). In many cases, as described in Section 2 of this impact assessment, Special Purpose Lamps are instead used for general lighting purposes. While it is not possible to estimate per exemption how this has been used as a loophole, and thus quantify the lost energy savings per exemption, the evaluation showed that the ambiguity in the formulation of the exemptions taken together is one of the causes for the gap between the expected and the real energy savings at 2020 presented in Section 2 (70 TWh/y instead of expected 110 TWh/y).

List of exemptions proposed in the review of the ecodesign regulation

The proposed exemptions aim at tackling the ambiguities of the current regulations. The approach is to abandon the principle of "intended use" of a light source and its special purpose and to define exemptions clearly verifiable because based on legislation and/or technical characteristics.

The review proposes three groups of exemptions:

1.The reviewed Regulation should not apply to light sources and separate control gears specifically tested and approved to operate:

(a)in potentially explosive atmospheres as defined in Directive 2014/34/EU of the European Parliament and of the Council;

(b)for emergency use as set out in Directive 2014/35/EU of the Council and the Parliament;

(c)in radiological and nuclear medicine installations, as defined in Article 3 of Directive 2009/71/EURATOM;

(d)in or on military or civil defence establishments, equipment, ground vehicles, marine equipment or aircraft as set out in Member States’ Regulations or in documents issued by the European Defence Agency;

(e)in or on motor vehicles, their trailers and systems, components, interchangeable towed equipment and separate technical units intended as set out in Regulation No 661/2009, Regulation (EU) No 168/2013, Regulation (EU) No 167/2013 and their amendments;

(f)non-road mobile machinery intended as set out in Regulation (EU) 2016/1628/EU and their amendments;

(g)in or on civil aviation aircrafts as set out in Commission Regulation 748/2012;

(h)in railway vehicle lighting as set out in Directive 2008/57/EC and its amendments, as well as relevant Member State legislation;

(i)in marine equipment as set out in Council Directive 2014/90/EU and its amendments or recasts;

(j)in medical devices as set out in Council Directive 93/42/EEC and in vitro medical devices as set out in Directive 98/79/EC and their amendments.

For these exemptions, ‘specifically tested and approved’ means that the light source or separate control gear:

–has been specifically tested for the mentioned operating condition or application, according to the indicated European legislation or related implementing acts, relevant Member State legislation, and/or relevant European or international standards; and

–is accompanied by evidence, in the form of a certificate, a type approval mark, a test report or other documentation, that the product has been specifically approved for the mentioned operating condition or application; and

–is placed on the market specifically for the mentioned operating condition or application, as evidenced at least by the technical documentation, information on the packaging and any advertising or marketing materials.

2.In addition, the reviewed Regulation should not apply to:

(a)double capped fluorescent T5 light sources with power P ≤ 13 W;

(b)electronic displays (e.g. televisions, computer monitors, notebooks, tablets, mobile phones, e-readers, game consoles), including but not limited to displays in scope of Commission Regulation (EU) No 617/2013, Commission Decision (EU) 2015/1402, Commission Regulation (EC) No 642/2009, Commission Decision (EU) 2016/1756, European Commission COM(2015)178;

(c)Range hoods in the scope of Commission Delegated Regulation (EU) No 65/2014;

(d)light sources and separate control gears in battery-operated products, including but not limited to e.g. torches, mobile phones with integrated torch light, toys including light sources, desk lamps operating only on batteries, armband lamps for cyclists, solar-powered garden lamps;.

(e)light sources and separate control gears in bicycles and other non-motorized vehicles.

3.The following light source or separate control gear should comply only with information requirements because they have a specific technical design:

(a)signalling (including, but not limited to, road-, railway-, marine- or air traffic- signalling, traffic control or airfield lamps);

(b)image capture and image projection (including, but not limited to, photocopying, printing (directly or in pre-processing), lithography, film and video projection, holography);

(c)light sources with specific effective ultraviolet power >2 mW/klm and intended for use in applications requiring high UV-content;

(d)light sources having the peak radiation around 253.7 nm and intended for germicidal use (destruction of DNA);

(e)light sources emitting 5% or more of total radiation power of the range 250-800 nm in the range of 250-315 nm and/or 20% or more of total radiation power of the range 250-800 nm in the range of 315-400 nm, and intended for disinfection or fly trapping;

(f)light sources having the primary purpose to emit radiation around 185.1 nm and intended to be used for the generation of ozone;

(g)light sources emitting 40% or more of total radiation power of the range 250-800 nm in the range of 400-480 nm, and intended for coral zooxanthellae symbioses;

(h)FL light sources emitting 80% or more of total radiation power of the range 250-800 nm in the range of 250-400 nm, and intended for sun-tanning;

(i)HID light sources emitting 40% or more of total radiation power of the range 250-800 nm in the range of 250-400 nm, and intended for sun-tanning;

(j)light sources with a photosynthetic efficacy >1.2 µmol/J, and/or emitting 25% or more of total radiation power of the range 250-800 nm in the range of 700-800 nm, and intended for use in horticulture;

(k)HID light sources with correlated colour temperature CCT > 7000 K and intended for use in applications requiring such a high CCT;

(l)halogen light sources with a beam angle of less than 10˚ and intended for spot-lighting applications requiring a very narrow light beam;

(m)halogen light sources with cap-type G9.5, GX9.5, GY9.5, GZ9.5, G9.5HPL, G16d, GX16, GX16d, GY16, G22, G38, GX38, GX38Q, P28s, P40s, PGJX50, QXL, designed and marketed specifically for scene-lighting use in film-studios, TV-studios, and photographic-studios, or for stage-lighting use in theatres, discos and during concerts or other entertainment events;

(n)Colour-tuneable light sources that can be set to at least the colours mentioned in table below and have for each of these colours, measured at the dominant wavelength, a minimum colour purity index according to table below, and intended for use in applications requiring high-quality coloured light:

Colour Dominant wave-length range Minimum colour purity index

Blue 440nm – 490nm 90%

Green 520nm – 540nm 65%

Red 610nm – 670nm 95%

(o)light sources accompanied by an individual calibration certificate detailing the exact radiometric flux and/or spectrum under specified conditions, and intended for use in photometric calibration (of e.g. wavelength, flux, colour temperature, colour rendering index), or for laboratory use during the evaluation of coloured surfaces and materials under standard viewing conditions (e.g. standard illuminants);

(p)light sources provided specifically for use by photosensitive patients, to be sold in pharmacies and other authorised selling points like disability products suppliers on presentation of a medical prescription;

(q)Incandescent light sources (not including halogen light sources) fulfilling all of the following conditions: power ≤40W, length ≤60mm, diameter ≤30mm, declared suitable for operation at ambient temperature ≥300°C, and intended for use in high temperature applications such as ovens;

(r)Halogen light sources fulfilling all of the following conditions: cap-type G4, GY6.35 or G9, power ≤60W, declared suitable for operation at ambient temperature ≥300°C, and intended for use in high temperature applications such as ovens;

(s)Light sources and separate control gears intended for operation at ambient temperatures below -30°C.

General warning for the comparison with the exemptions in the current legislation

It is challenging to make a clear overview of how exemptions will change from the existing regulations to new regulation. One main reason is that the three existing regulations do not have exactly the same scope and do not use the same exemptions.

A second reason is that there are descriptions in the existing regulations that are vague and open to interpretation, and that therefore a list of products being exempted by them is difficult to define and seemingly unlimited. This is the case, for example, of exemptions based on the fact that the primary purpose of a light is not lighting, or when the light source does not provide a general lighting function.

A third reason is that there are overlaps between scope, generic exemptions and specific exemptions, i.e. a given light source may be excluded from the regulation for more than one reason. Hence, dropping an exemption does not always mean that the associated light sources are no longer exempted.

Main exemptions that were discussed among stakeholders

1. Stage lighting: in the current regulations there is an exemption for stage lighting, meaning in theatres, concert stages, TV and similar contexts. The exemption has been widely interpreted, by including all lighting within the perimeter of the location (e.g. lighting of the entrance hall of the theatre). The total consumption for theatre et al. lighting is estimated at 3 TWh/y, of which only 0.075 TWh/y for lighting on stage. The approach to define the exemption has been to identify the specific light sources used only on stage: this was possible looking at the socket types.

2. Colour tuneable lighting: this is connected to stage lighting too. The current regulations are ambiguous about having in scope or not colour tuneable lighting. This was a consequence of the slightly wider white light area of one of the three regulations. The proposed review clarifies the exemption for colour tuneable lighting based on the index colour purity.

3. Handling equipment: in the current regulation the exemption is quite vague. A specific exemption is proposed based on legislation and per motor vehicle type with the support of the European associations representing manufacturers of handling equipment.

4. Photosensitive patients: the current regulations have a general exemption for photosensitive patients to buy incandescent light sources, which were phased out from 2009. Some Member States reported that incandescent lamps are still present in shops for general lighting uses. Several reports have shown that there is no evidence that other lighting technologies than incandescents cause health effects: however, being a sensitive point, the proposed review keeps the exemption for photosensitive patients but requires to buy the specific light sources in pharmacies and with a medical prescription.

5. Railway platforms and tunnels: some Member States and the railway sector asked to check exemptions to avoid LEDs on tunnels and platforms. At the beginning the request from the railway sector was, like for theatres, to exempt the entire perimeter of the railway area, including offices or passengers corridors (the current regulations could be read as allowing for this). Despite several analysis and conversations with the sector, it was no possible to define an exemption bases on safety or technical requirements set in legislation, or technical require. On the other hand, there are examples of safe use of LEDs, especially in tunnels, already.

Abbreviations in the table:

|  |  |
| --- | --- |
| CC | Chromaticity coordinates |
| SPL | Special Purpose Lamp |
| LS | Light source |
| WD | Proposed Working Document |
| FLni | Fluorescent lamp without integrated ballast |
| HID | High-intensity discharge lamp |
| NDHHL | non-directional household lamps, including when they are marketed for non-household use or when they are integrated into other products, as defined in 244/2009 |
|  | ‘household lamp’ means a lamp intended for household room illumination; it does not include special purpose lamps; |
|  | 'lamp’ means a source made in order to produce an optical radiation, usually visible, including any additional components necessary for starting, power supply or stable operation of the lamp or for the distribution, filtering or transformation of the optical radiation, in case those components cannot be removed without permanently damaging the unit |
|  | ‘household room illumination’ means the full or partial illumination of a household room, by replacing or complementing natural light with artificial light, in order to enhance visibility within that space |
|  | The definition of DLS and NDLS in Commission Regulation (EC) No 244/2009 is the same as in the WD |
| DLS | Directional light source |
| NDLS | Non-directional light source |
| 244/2009 | Commission Regulation (EC) No 244/2009 |
| 245/2009 | Commission Regulation (EC) No 245/2009 |
| 1194/2012 | Commission Regulation (EU) No 1194/2012 |

Table comparing the exemptions:

|  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- |
|  |  | PROPOSED WORKING DOCUMENT | | | | |  |
| EXISTING REGULATIONS |  | REMAINS EXEMPTED | | NOT EXEMPTED | |  |  |
| OUT-OF-SCOPE OR EXEMPTED | ADDITIONAL INFORMATION | MOVED OUT-OF-SCOPE | EXPLICIT EXEMPTION | REMAINS NON-EXEMPTED | NO LONGER EXEMPTED | IMPROVED CLARITY | CHANGE IN ENERGY SAVINGS (EXCLUDING DIFFERENT USES) |
| Out-of-scope or exempted in Commission Regulation (EC) No 244/2009 (Non-directional household lamps) | | | | | | | |
|  |  |  |  |  |  |  |  |
| NDHHL | The 244/2009 definition leaves ample room for interpretation. In WD the concept of 'household lamp' is no longer used. See subtypes on separate rows |  |  |  |  | x |  |
| NDHHL in/on means of transport | In 244/2009 assumed implicitly exempted due to text in Directive 2009/125/EC Art.1.3. |  | x |  |  | x | none |
| LS for use in household appliances other than range hoods and ovens | In 244/2009 these LS have generally been considered to be not NDHHL (not for household room illumination). In WD there is no explicit exemption, because adequate LED retrofit lamps are available. |  |  |  | x |  | Additional energy saving < 0.6 TWh/a |
| LS for use in range hoods | In 244/2009 same as above. In WD explicit exemption, to avoid interaction with specific regulation on range hoods. |  | x |  |  | x | none |
| LS for use in ovens / microwave ovens | In 244/2009 same as above. In addition in 244/2009 high temperature exemption, see further below. In WD exemption for high temperature use. |  | x |  |  | x | none |
| decorative lamps | In 244/2009 these have sometimes been considered to be not NDHHL (not for household room illumination), or to be SPL because their primary purpose is not lighting. EC interpretation is that 'decorative lamps' were not exempted in 244/2009. In WD there is also no explicit exemption. |  |  | x |  | x | none |
| directional lamps | Exempted in 244/2009 because covered separately in CR 1194/2012. WD uses same definition for what is DLS/NDLS. |  |  | x |  |  | none |
| fluorescent lamps without integrated ballast | Exempted in 244/2009 because covered separately in 245/2009 |  |  | x |  |  | none |
| high-intensity discharge lamps | Exempted in 244/2009 because covered separately in 245/2009 |  |  | x |  |  | none |
| non-white lamps, Chromaticity Coordinates x-y | WD has smaller 'white light' area and thus puts more (non-white) LS out-of-scope. This is intentional, to have less need for specific exemptions. In 244/2009 more lamps were in scope but then later exempted with a rather vague description. The overall effect is more or less the same. | several LS exempted in 244/2009 now moved out-of-scope (effect is more or less the same) |  |  |  | x | none |
| NDHHL with CC x < 0,200 | WD: LS with CC x < 0,270 |  |  |  |  |  |  |
| NDHHL with CC x > 0,600 | WD: LS with CC x > 0,530 |  |  |  |  |  |  |
| NDHHL with CC y < – 2,3172 x2 + 2,3653 x – 0,2800 | WD: LS with CC y < – 2,3172 x2 + 2,3653 x – 0,2200 |  |  |  |  |  |  |
| NDHHL with CC y > – 2,3172 x2 + 2,3653 x – 0,1000 | WD: LS with CC y > – 2,3172 x2 + 2,3653 x – 0,1595 |  |  |  |  |  |  |
| NDHHL with flux < 60 lm | WD identical to 244/2009: same lower limit for flux. | x |  |  |  |  | none |
| NDHHL with flux > 12000 lm (relevant mainly for halogen lamps used in studio-/stage-/event-lighting) | WD: uses upper flux limit 82000 lm, used in existing CR for HPS and now applied to all LS types. WD draws into scope e.g. halogen lamps with flux between 12000 and 82000 lm. In part this is possible because adequate LED replacements exist (LED flood lights instead of Halogen R7s). In part these lamps are now exempted based on their cap-type and their use in studio- and stage-lighting. |  | Halogen with certain cap-types for use in studio/stage lighting |  | Halogen with flux between 12 and 82 klm now in scope |  | extra savings on R7s > 12000 lm are < 0.1 TWh/a |
| NDHHL having 6 % or more of total radiation of the range 250-780 nm in the range of 250-400 nm | WD: UV lamps continue to be not regulated: or out-of-scope for non-white, or specific exemption. | most UV | some UV |  |  |  | none |
| NDHHL having the peak of the radiation between 315-400 nm (UVA) or 280-315 nm (UVB) | WD: UV lamps continue to be not regulated: or out-of-scope for non-white, or specific exemption. | most UV | some UV |  |  |  | none |
| NDHHL incandescent lamps with E14/E27/B22/B15 caps, with a voltage equal to or below 60 volts and without integrated transformer in Stages 1-5 according to Article 3. | No longer relevant from Stage 6 (September 2018). Hence no action on these in WD. |  |  | x |  |  | none |
| NDHHL SPL (generic): applications where the primary purpose of the light is not lighting | Some examples of this are mentioned in 244/2009 (see rows below), but as a generic exemption this was very vague. See e.g. separate entry for 'decorative lamps'. This formulation intentionally avoided in WD. |  |  |  |  | x | expected small, but not quantifiable |
| NDHHL SPL: emission of light as an agent in chemical or biological processes (such as polymerisation, ultraviolet light used for curing/drying/hardening, photodynamic therapy, horticulture, pet care, anti-insect products) | Most of these lamps are UV. In WD, UV lamps continue to be not regulated: or out-of-scope for non-white, or specific exemption. | most UV, most horticulture | some UV, some horticulture |  |  |  | none |
| NDHHL SPL: image capture and image projection (such as camera flashlights, photocopiers, video projectors) | Some probably moved out-of-scope for light density criterion. Anyway same exemption also in WD. | some | x |  |  |  | none |
| NDHHL SPL: heating (infrared lamps) | In WD assumed to be out-of-scope because non-white. | x |  |  |  | x | none |
| NDHHL SPL: signalling (such as traffic control or airfield lamps) | Same exemption is also in WD. |  | x |  |  |  | none |
| NDHHL SPL: the spectral distribution of the light is intended to change the appearance of the scene or object lit, in addition to making it visible (such as food display lighting or coloured lamps as defined in point 1 of Annex I), with the exception of variations in correlated colour temperature | In WD, as in 244/2009, coloured lamps are already out-of-scope, but there are more out-of-scope in WD (see separate entry on chromaticity coordinates). For food display lighting, some may be out-of-scope for non-white. For many food lighting applications adequate LED retrofits are available. No specific exemption based on spectral characteristics could be formulated. | most |  |  | some |  | negligible |
| NDHHL SPL: the spectral distribution of the light is adjusted to the specific needs of particular technical equipment, in addition to making the scene or object visible for humans (such as studio lighting, show effect lighting, theatre lighting) | In WD, there is a specific exemption for halogen lamps with certain cap-types, that intend to cover all halogen lamps used in studio-, stage-, and event-lighting |  | x |  |  | x | none |
| NDHHL SPL: the scene or object lit requires special protection from the negative effects of the light source (such as lighting with dedicated filtering for photosensitive patients or photosensitive museum exhibits) | LS suppliers are promoting use of LEDs in museums because they have less negative effects. Therefore exemption for museum not continued. Same should partly be true for photosensitive patients, i.e. LEDs permit to fine-tune the spectrum, but uncertain if such LEDs can meet efficiency requirements. |  | for photo-sensitive patients |  | for museum exhibits |  | extra savings for museum lighting < 0.06 TWh/a |
| NDHHL SPL: lighting is required only for emergency situations (such as emergency lighting luminaires or control gears for emergency lighting) | WD: emergency lighting continues to be exempted |  | x |  |  |  | None |
| NDHHL SPL: the lighting products have to withstand extreme physical conditions (such as vibrations or temperatures below – 20 °C or above 50 °C) (however, see limitations on exemption for shock-proof below) | WD: upper temperature limit made more specific for incandescents and halogen used in ovens. Use in range hoods explicitly exempted (see separate entry). In WD, lower limit decreased to -30C (LEDs have no problem at lower temperature). In WD no exemption for shock-/vibration proof (LEDs have good resistance) Limitation on exemption for shock-/vibration resistant introduced in CR 2015/1428, to close some loopholes in 244/2009: Incandescent lamps longer than 60 mm are not special purpose lamps, if they are resistant only to mechanical shock or vibrations and are not incandescent traffic signalling lamps; or they possess a rated power higher than 25 W and claim to have specific features that are also present in lamps having higher energy efficiency classes according to Regulation (EU) No 874/2012 (such as zero EMC emissions, CRI value higher or equal to 95, and UV emissions less or equal than 2 mW per 1 000 lm) |  | LS for extreme temperatures, range hoods |  | vibration- and shock-resistance | x | negligible |
| Out-of-scope or exempted in Commission Regulation (EC) No 245/2009 (FL and HID without integrated ballast) | | | | | | | |
| FLni-HID that are not white light sources as defined in Annex II; this exemption does not apply to high pressure sodium lamps | WD uses the same definition for white light as 245/2009 and makes the same exemption for HPS | x |  |  |  |  | none |
| FLni-HID that are directional light sources as defined in Annex II | Exempted in 245/2009 because covered separately in CR 1194/2012. WD uses same definition for what is DLS/NDLS. |  |  | x |  |  | none |
| blended high intensity discharge lamps having:  — 6 % or more of total radiation of the range 250-780 nm in the range of 250-400 nm; and  — 11 % or more of total radiation of the range 250-780 nm in the range of 630-780 nm; and  — 5 % or more of total radiation of the range 250-780 nm in the range of 640-700 nm | Blended lamp is an incandescent lamp in series with a high-pressure mercury lamp in the same bulb. In WD, blended HID are in scope (combination of technologies). Industry has proposed to apply this exemption to all LS and to consider each condition separately instead of all together, but that would increase risk of abuse, while industry did not demonstrate the actual need to maintain this exemption. Impression is that it is an old technology, no longer necessary. RoHS might also block these lamps for their mercury content. In WD assumed that no specific exemption is necessary in addition to related exemptions and out-of-scope that are already formulated. | non-white UV- and IR-light sources | horticulture LS, several types of UV LS |  | some types of blended lamps |  | very small, but not quantifiable |
| blended high intensity discharge lamps having:   — the peak of the radiation between 315-400 nm (UVA) or 280-315 nm (UVB) | See remarks above. There are similar exemptions / out-of-scope in WD, but may be slightly different and not specific for blended lamps | most UV (non-white) | several types of UV |  | some types of blended lamps |  | negligible |
| double capped fluorescent lamps having a diameter of 7 mm (T2) and less | agreed with stakeholders that this exemption is no longer necessary, so no exemption in WD |  |  |  | x |  | very small, but not quantifiable |
| double capped fluorescent lamps having a diameter of 16 mm (T5) and lamp power P ≤ 13 W or P > 80 W | The exemption for P < 13W has been maintained in WD. Exemption for > 80W regards very few lamps (if any), and they can meet requirements, so exemption has been discontinued. |  | T5 ≥ 13 W |  | T5 > 80 W |  | none or negligible |
| double capped fluorescent lamps having a diameter of 38 mm (T12), lamp cap G-13 Medium BiPin base, +/– 5 m (+magenta, –green) colour compensating filter value limit (cc). CIE coordinates x=0,330 y=0,335 and x=0,415 y=0,377 | Industry has not been able to indicate where these very specific lamps are being used and why an exemption would still be necessary. Hence, exemption is no longer in WD. |  |  |  | x |  | none or negligible |
| double capped fluorescent lamps having a diameter of 38 mm (T12) and equipped with an external ignition strip | agreed with stakeholders that this exemption is no longer necessary, so no exemption in WD |  |  |  | x |  | very small, but not quantifiable |
| single capped fluorescent lamps having a diameter of 16 mm (T5), 2G11 4-pin base, Tc= 3200 K with chromaticity coordinates x=0,415 y=0,377 and Tc=5500 K with chromaticity coordinates x=0,330 y=0,335 | Industry has not been able to indicate where these very specific lamps are being used and why an exemption would still be necessary. Hence, exemption is no longer in WD. |  |  |  | x |  | none or negligible |
| high intensity discharge lamps with Tc > 7 000 K | the same exemption is present in the WD |  | x |  |  |  | none |
| high intensity discharge lamps having a specific effective UV output > 2 mW/klm | In WD, following stakeholder comments, this exemption has been extended to all LS, not only HID, because use of LS with UV > 2 mW/klm is not allowed in general lighting applications | several | exemption extended to all LS |  |  |  | none or negligible |
| high intensity discharge lamps not having lamp cap E27, E40, PGZ12 | The limitation to certain cap-types has been dropped in the WD because analysis showed that most HID with other cap types also meet requirements. Stakeholders have not protested against this. Many of the concerned LS anyway continue to be out-of-scope because they have a high light density or because they have a flux > 82000 lm. Practically all HID used for studio-,stage- and event-lighting continue to be exempted for these other reasons. | many, with high light density and/or flux > 82000 lm |  |  | some, but almost all meet the requirements |  | none or negligible |
| FLni-HID in/on means of transport | In 245/2009 assumed implicitly exempted due to text in Directive 2009/125/EC Art.1.3. EC changed interpretation on this. Therefore now explicitly exempted in WD |  | x |  |  | x | none |
| products intended for use in applications other than general lighting and products incorporated into products which do not provide a general lighting function. Where: ‘general lighting’ means substantially uniform lighting of an area without provision for special local requirements | This is a sort of generic exemption to cover products for which a specific exemption was forgotten, or not possible to formulate. In part it overlaps with more specific exemptions. In addition it is open to interpretation. This makes it difficult to draw up a list of additional products being exempted by this, but some possible examples of NDLS FLni-HID exempted by this follow on separate rows below. The list cannot be exhaustive. The exemption was considered too vague to be re-used in the WD, but some products have been specifically exempted in WD. |  |  |  |  | x | see rows below |
| NDLS FLni-HID used for signalling and signage, e.g. neon and (static) billboards, exit signs | Signalling lamps continue to be exempted in WD. Neon lamps are out-of-scope. Exit signs often use T5 < 13W that are exempted | neon lamps, non-white | signalling, T5 < 13W |  |  |  | none |
| Aquariums | Industry was not able to define specific measurable criteria for LS used for aquariums. Rather than using a vague exemption based on intended use, it was preferred not to have an exemption. | some non-white | some UV, some T5 < 13W |  | several |  | additional saving 0.5 TWh/a |
| Non-residential appliances (refrigerators, freezers, laundry equipment, range hoods, vending machines, automatic dispensers, machine tools, elevators, escalators; ovens excluded) | For most of these applications adequate LED retrofits are expected to be available. FL T5 and HID remain on the market. In WD no exemption deemed necessary. |  | some T5 < 13W |  | several |  | additional saving 0.5 TWh/a |
| image capture and image projection | In WD there is an explicit exemption for this |  | x |  |  |  | none |
| medical lamps | In WD there is an explicit exemption for this |  | x |  |  |  | none |
| HID for studio-, stage-, event-lighting | Practically all HID used for studio-,stage- and event-lighting continue to be exempted for high light density or for flux > 82000 lm. No specific exemption necessary. (See section on 244/2009 for halogen lamps used in these applications) | almost all for >500 lm/mm2 or > 82000 lm | some with CCT > 7000K |  |  |  | none |
| horticulture lamps | Many non-white or with specific UV > 2 mW/klm. In WD there is anyway also an explicit exemption for horticulture based on spectral characteristics. | many non-white | x |  |  |  | none |
| UV resulting to be white light (e.g. possibly germicidal, disinfection, fly trapping, ozone generation, coral growth, suntanning) | Most UV expected to be non-white, but where specific spectrum-based exemptions for UV-lights could be defined, these have been inserted in WD. |  | most |  | some |  | negligible |
| food display lighting | Several may be out-of-scope for non-white. For many food lighting applications adequate LED retrofits are available. No specific exemption based on spectral characteristics could be formulated. | several non-white |  |  | some |  | additional saving 0.1 TWh/a |
| scientific lamps | In WD, there is a specific exemption for calibration lamps. Impossible to find a measurable criterion for exemption of all lamps in this heterogeneous group | some non-white, or high light density | LS with calibration certificate |  | several |  | negligible |
| infrared (IR) and collagen lamps | In WD assumed to be all out-of-scope for non-white. | x |  |  |  |  | none |
| electronic displays and backlighting for displays | In WD there is a specific exemption |  | x |  |  |  | none |
| data-communication and laser applications | In WD out-of-scope for non-white, or high light density, or flux < 60 lm, or CRI < 0, or technology out-of-scope | x |  |  |  |  |  |
| lamps covered by the requirements of Directives 94/9/EC or Directive 1999/92/EC | This regards LS for use in potentially explosive atmospheres. The same exemption is present in WD but with reference to up-to-date legislation. |  | x |  |  |  | none |
| emergency lighting luminaires and emergency sign luminaires within the meaning of Directive 2006/95/EC | The same exemption is in WD, but with updated reference to legislation |  | x |  |  |  | none |
| ballasts intended for use in luminaires defined in paragraph (c) and designed to operate lamps in emergency conditions | The same exemption is in WD, but with updated reference to legislation |  | x |  |  |  | none |
| luminaires covered by the requirements of Directive 94/9/EC, Directive 1999/92/EC, Directive 2006/42/EC, Council Directive 93/42/EEC, Council Directive 88/378/EEC and luminaires integrated into equipment covered by these requirements | Directive 94/9/EC, Directive 1999/92/EC regard explosive atmospheres; Directive 2006/42/EC regards Machinery; Council Directive 93/42/EEC regards medical devices; Council Directive 88/378/EEC regards safety of toys. The WD explicitly exempts LS for use in explosive atmospheres and in medical devices. The WD does not refer to the Machinery Directive or the Directive on safety of toys. Note however that WD applies to LS and not to luminaires, so there is no need to exempt certain types of luminaire. |  | LS for explosive atmosphere, medical devices. Battery-operated LS (e.g. for toys) |  | luminaires covered by machinery directive, but new regulation does usually not apply to luminaires |  | none |
| high pressure sodium lamps with Ra ≤ 60 and power > 605W. | These lamps are not actually exempted, but in 1194/2012 there are no energy efficiency requirements for them. The limit of 605W, with corresponding required efficiency of 135 lm/W (clear lamps) implies 82000 lm. This is the same flux limit as applied in WD for all light sources | HPS with Ra < 60 and flux > 82000 lm |  |  |  | x | none |
| high pressure sodium lamps with Ra > 60 and power > 405W. | These lamps are not actually exempted, but in 1194/2012 there are no energy efficiency requirements for them. The limit of 405W, with corresponding required efficiency of 85 lm/W (clear lamps) implies 34000 lm. In WD the upper flux limit is 82000 lm, so HPS with Ra>60 and flux between 34000 and 82000 lm are drawn into scope. There are very few models that are affected and they can meet efficiency requirements, so there is no effect. |  |  |  | HPS with Ra>60 and flux between 34000 and 82000 lm | x | none |
| metal-halide lamps with power > 405 W | These lamps are not actually exempted, but in 1194/2012 there are no energy efficiency requirements for them. The limit of 405W, with corresponding required efficiency of 90 lm/W (clear lamps) implies 36000 lm. In WD the upper flux limit is 82000 lm, so MH with flux between 36000 and 82000 lm are drawn into scope. Special efficiency requirements have been set for these LS so that they can stay on the market. |  |  |  | MH with flux between 36000 and 82000 lm | x | none |
|  |  |  |  |  |  |  |  |
| Out-of-scope or exempted in Commission Regulation (EU) No 1194/2012 (Directional lamps + functional requirements for all LED) | | | | | | | |
| LED modules marketed as part of luminaires that are placed on the market in less than 200 units per year. | Sales quantities are too difficult for MSA to verify and hence this exemption has not been copied to the WD. Stakeholders have not protested against removal. |  |  |  | x |  | none |
| non-white lamps, with range of CC x-y defined in 1194/2012. | Different from 244/2009, in 1194/2012 non-white lamps are not actually exempted, but they are SPL, so subject only to information requirements. In WD, non-white LS are out-of-scope, so also without information requirements. The definition of 'white-light' in 1194/2012 is the same as in the WD. | x |  |  |  |  | none |
| (no flux limits) | In 1194/2012 there are no flux limits, while WD puts out-of-scope LS with < 60 lm or > 82000 lm. This change regards very few DLS models, if any. LED NDLS with low flux are affected, and this is intentional. | new: LS with flux < 60 lm or flux > 82000 lm |  |  |  |  | none |
| DLS or LED SPL (generic): applications where the primary purpose of the light is not lighting | Some examples of this are mentioned in 1194/2012 (rows below), but as a generic exemption this was very vague. This formulation intentionally avoided in WD. |  |  |  |  | x | expected small, but not quantifiable |
| DLS or LED SPL: emission of light as an agent in chemical or biological processes (such as polymerisation, ultraviolet light used for curing/drying/hardening, photodynamic therapy, horticulture, pet care, anti-insect products) | Most of these lamps are UV. In WD, UV lamps continue to be not regulated: or out-of-scope for non-white, or specific exemption | most UV, most horticulture | some UV, some horticulture |  |  |  | none |
| DLS or LED SPL: image capture and image projection (such as camera flashlights, photocopiers, video projectors) | Some probably moved out-of-scope for light density criterion. Anyway same exemption also in WD. | some | x |  |  |  | none |
| DLS or LED SPL: heating (infrared lamps) | In WD assumed to be out-of-scope because non-white | x |  |  |  | x | none |
| DLS or LED SPL: signalling (such as traffic control or airfield lamps) | Same exemption is also in WD |  | x |  |  |  | none |
| DLS or LED SPL: the spectral distribution of the light is intended to change the appearance of the scene or object lit, in addition to making it visible (such as food display lighting or coloured lamps as defined in point 1 of Annex I), with the exception of variations in correlated colour temperature | In 1194/2012, coloured lamps are SPL (only info requirements). In WD, coloured lamps are out-of-scope. See also remarks for non-white in 1194/2012 above. For food display lighting, some may be out-of-scope for non-white. For many food lighting applications adequate LED retrofits are available. No specific exemption based on spectral characteristics could be formulated. | most |  |  | some |  | negligible |
| DLS or LED SPL: the spectral distribution of the light is adjusted to the specific needs of particular technical equipment, in addition to making the scene or object visible for humans (such as studio lighting, show effect lighting, theatre lighting) | In WD, there is a specific exemption for halogen lamps with certain cap-types, that intend to cover all halogen lamps used in studio-, stage-, and event-lighting |  | x |  |  | x | none |
| DLS or LED SPL: the scene or object lit requires special protection from the negative effects of the light source (such as lighting with dedicated filtering for photosensitive patients or photosensitive museum exhibits) | LS suppliers are promoting use of LEDs in museums because they have less negative effects. Therefore exemption for museum not continued. Same should partly be true for photosensitive patients, i.e. LEDs permit to fine-tune the spectrum, but uncertain if such LEDs can meet efficiency requirements. |  | for photo-sensitive patients |  | for museum exhibits |  | extra savings for museum lighting < 0.06 TWh/a (double counted with 244/2009) |
| DLS or LED SPL: lighting is required only for emergency situations (such as emergency lighting luminaires or control gears for emergency lighting) | WD: emergency lighting continues to be exempted |  | x |  |  |  | none |
| DLS or LED SPL: the lighting products have to withstand extreme physical conditions (such as vibrations or temperatures below – 20 °C or above 50 °C) (however, see limitations on exemption for shock-proof below) | WD: upper temperature limit made more specific for incandescents and halogen used in ovens. Use in range hoods explicitly exempted (see separate entry). In WD, lower limit decreased to -30C (LEDs have no problem at lower temperature). In WD no exemption for shock-/vibration proof (LEDs have good resistance) |  | extreme temperatures, range hoods |  | vibration- and shock-resistance | x | small, but not quantifiable |
| DLS or LED SPL: products incorporating lighting products, where the primary purpose is not lighting and the product is dependent on energy input in fulfilling its primary purpose during use (such as refrigerators, sewing machines, endoscopes, blood analysers) | This exemption was considered too vague to be re-used in the WD, but some products have been specifically exempted in WD. No exemption was deemed necessary for e.g. refrigerators and sewing machines because LED retrofits are available there. |  | LS for medical devices, range hoods, high temperature (ovens), low temperature (freezers) |  | LS for household appliances (except range hoods, ovens, freezers) | x | small, but not quantifiable |
| DLS or LED in/on means of transport | In 1194/2012 assumed implicitly exempted due to text in Directive 2009/125/EC Art.1.3. EC changed interpretation on this. Therefore now explicitly exempted in WD |  | x |  |  | x | none |
|  |  |  |  |  |  |  |  |
| New out-of-scope or exempted in WD, while not clearly exempted in existing regulations | | | | | | | |
|  |  |  |  |  |  |  |  |
| LS in radiological and nuclear medicine installations, as defined in Article 3 of Directive 2009/71/EURATOM | Precautionary principle; very low energy impact |  | x |  |  |  | negligible |
| LS in or on military or civil defence establishments, equipment, ground vehicles, marine equipment or aircraft as set out in Member States’ Regulations or in documents issued by the European Defence Agency | Precautionary principle; very low energy impact |  | x |  |  |  | negligible |
| light sources and separate control gears in battery-operated products, including but not limited to e.g. torches, mobile phones with integrated torch light, toys including light sources, desk lamps operating only on batteries, armband lamps for cyclists, solar-powered garden lamps | Not feasible/worthwhile to verify for MSA |  | x |  |  |  | not quantifiable |
| halogen light sources with a beam angle of less than 10˚ and intended for spot-lighting applications requiring a very narrow light beam | In general, WD phases-out halogen light sources, but for spots with very narrow beam there are no adequate LED retrofits available yet. |  | x |  |  |  | small but not quantifiable |
| colour-tuneable light sources that can be set to at least the colours mentioned in table below and have for each of these colours, measured at the dominant wavelength, a minimum colour purity index according to table below, and intended for use in applications requiring high-quality coloured light:  Colour Dominant wave-length range Minimum colour purity index  Blue 440nm – 490nm 90%  Green 520nm – 540nm 65%  Red 610nm – 670nm 95% | New in WD is the specific treatment of colour-tuneable light sources (CTLS). There are specific requirements for them. However CTLS that work with RGB LEDs cannot produce white light with good efficiency, because they are optimized for coloured lighting. Rather than drawing up a very low efficiency requirement for these, they have been exempted. This does not exempt all CTLS. |  | x |  |  |  | small but not quantifiable |

  

Annex 12: Glossary

|  |  |
| --- | --- |
|  | Meaning or definition |
| AIE | European Association of Electrical Contractors |
| ANEC | European Association for the Co-ordination of Consumer Representation in Standardisation (NGO) |
| APPLiA | Home Appliances Europe, formerly CECED |
| BAT | Best Available Technology |
| BAU | Business-as-usual (describing a scenario without any further intervention) |
| BEUC | European Consumer Organisation (NGO) |
| bn | billion |
| CECAPI | European coordinating committee representing the Associations of Manufacturers of Electrical Installation Equipment within the member states of the European Union and the EFTA region |
| CEN/TC 169 | Technical committee n. 169 "Light and lighting" of CEN – European Committee for Standardization |
| CER | Committee of European Railways |
| CLASP | Collaborative Labeling and Appliance Standards Program |
| DG | Directorate General |
| ECOS | European Environmental Citizens Organisation for Standardisation (NGO) |
| EEB | European Environment Bureau (NGO) |
| EEE | Electrical and Electronic Equipment |
| EEI | Energy Efficiency Index |
| EFIC | European Furniture Industries Confederation |
| EIM | European Rail Infrastructures Managers |
| ETS | Emissions Trading Scheme |
| EU | European Union |
| EucoLight | European association of collection and recycling organisations for WEEE lamps and lighting |
| EUR | Euro currency |
| EURIC | European Recycling Industries’ Confederation |
| EuroCommerce | European Association for Retail and Wholesale |
| GfK | Growth from Knowledge |
| GHG | Greenhouse gas |
| GWP | Global Warming Potential |
| IALD | International Association of Lighting Designers |
| IEA | International Energy Agency |
| IEC | International Electrotechnical Commission; global standardisation organisation |
| kg | kilogram |
| kWh | kilo Watt hour, 103 Watt per hour (unit of energy) |
| LCC | Life cycle cost over the whole lifetime of a product, including purchase cost and energy costs |
| LLCC | Least life cycle cost; used to determine the energy efficiency requirements that minimise costs of a product for its whole lifetime |
| M or mln | million |
| MEErP | Methodology for the Ecodesign of Energy-related Products [48](#footnote48) |
| MEEuP | Methodology for the Ecdesign of Energy-using Products |
| MEPS | Minimum Energy efficiency Performance Standards |
| Mt CO2 eq. | Mega tonne CO2 equivalent, 109 kg of gas equivalent to potency of CO2 (unit of GHG emissions) |
| Mtoe | Million Tonnes of Oil Equivalent |
| MS | Member State |
| MSA | Market Surveillance Authority (in charge of enforcing ecodesign regulation in a MS) |
| NGO | Non-Governmental Organisation e.g. ANEC, BEUC, ECOS, EEB |
| OEM | Original Equipment Manufacturer |
| ORGALIME | European Engineering Industries Association |
| o/w | Of which |
| R&D | Research and Development |
| REFIT | Regulatory Fitness and Performance |
| SME | Small and Medium-sized Enterprises |
| SVHC | Substances of Very High Concern |
| TopTen | International program to create a dynamic benchmark for the most energy efficient products |
| TWh | Tera Watt hour, 1012 Watt per hour (unit of energy) |
| VAT | Value Added Tax |
| VHK | Consultant company |
| WEEE | Waste Electrical and Electronic Equipment |
| Yr or a | Abbreviation used as denominator for units expressed per year (e.g. TWh/yr or TWh/a; EUR/y or EUR/a) |

Important Notice: This glossary aims to give non-experts a basic understanding of technical issues in this Impact Assessment report. Explanations are simplified and should not be used for any other purpose.

Lumen

The quantity of light emitted by a lamp is often measured in lumen (lm). A lamp emits a spectrum of electro-magnetic radiation, consisting of different wavelengths (colours), of which a large part cannot be perceived by the human eye. The other part (called light) still consists of different colours, and the sensitivity of the human eye depends on the colour. The lumen-measure takes these different sensitivities into account and consequently can be conceived as the useful amount of emitted light, as perceived by humans.

Input Power

All lamps considered here use electricity as input. The instantaneous amount of electrical input to a lamp is called the input power, expressed in Watt (W).

Efficacy / Efficiency

The efficacy of a lamp is the ratio of the light output (in lumen) and the power input (in Watt) and consequently expressed in lm/W. The term ‘efficacy’ is preferred over ‘efficiency’ because the latter is typically reserved for the ratio ‘output power’ / ‘input power’, while in the case of lamps the output is not a power. The efficacy may or may not include the efficiency of the ballast or control gear (see below in this glossary). This is clarified locally in the report where necessary.

Filament lamps or Incandescent lamps

When an electric current is made to pass through a thin metal wire (the ‘tungsten filament’), the metal opposes the current flow (electrical resistance) and as a result heats up and starts to glow (becomes ‘incandescent’), emitting electro-magnetic radiation of which a part is visible, called light. The main drawback of these lamps is that they have a low energy efficiency: around 90% of the input electricity is lost as heat. In addition the filament is slowly consumed during use, leading to a short lifetime (typically 1000-2000 burning hours).

GLS filament lamps

General Lighting Service (GLS) indicates the classical ‘Edison’ filament lamp design. These lamps dominated the sales until 2008-2010, but have now been phased-out due to Ecodesign regulations (except some special cases). They had an efficacy around 10 lm/W.

HL (Halogen) filament lamps

Halogen lamps are a modern version of the filament lamp. The main difference is that the filament is contained in a small capsule (often placed inside a larger bulb) that is filled with a halogen gas. This extends (typically doubles) the lifetime and also allows a slightly higher efficacy. HL are available in mains-voltage (230 V, can be attached directly to the electricity grid) or low-voltage (12 or 24 V, need a voltage transformer). These lamps have typical efficacies ranging from 12 to 20 lm/W. In recent years HLs have been popular as substitutes for the legacy GLS, but the current regulation imposes the phase-out of many HL-types in the coming years (2016-2018).

Fluorescent lamps (FL)

In a fluorescent lamp (tube) an electric current is made to pass through a gas that contains a small quantity (some milligrams) of low pressure mercury vapour. This vapour is excited by the current and emits an ultraviolet light, that is then converted to visible white light by a phosphor coating on the inside of the glass tube (fluorescence). The efficacy of fluorescent lamps is 50-100 lm/W, and thus 5-10 times higher than for filament lamps. Lifetimes for FLs range from 10 000 to 80 000 burning hours. These lamps cannot be connected directly to the electricity grid but need a ballast (control gear) to regulate the current. They are considered hazardous waste (separate collection) because they contain a small amount of mercury.

Linear Fluorescent lamps (LFL)

Linear fluorescent lamps are straight tube-like FLs. They are available in different lengths (e.g. 0.9, 1.2 and 1.5 m) and in different diameters (e.g. T12: 38 mm, T8: 26 mm, T5: 16 mm) and often applied for office lighting. The older models (T12 and T8 with less efficient halo-phosphor coating and higher mercury content) have now been phased-out due to Ecodesign regulations. LFL T8 with more efficient tri-phosphor coating have an efficacy around 80 lm/W (operating on electro-magnetic ballast). They are still widely used, but many have been substituted in recent years by the more modern LFL T5 with efficacy around 90 lm/W (operating on more efficient high-frequency electronic ballast).

Fluorescent Tx lamps (including T8)

'T2', 'T5', 'T8', 'T9' and 'T12' means a tubular light source with diameter of approximately 7, 16, 26, 29 and 38 mm respectively, as defined in harmonised standards. The tube can be straight (linear) or bent (e.g. U-shaped, circular).

‘LFL T8 2-foot’, ‘LFL T8 4-foot’ or ‘LFL T8 5-foot’ means a linear T8 fluorescent light source with a length of approximately 600 mm (2 feet), 1200 mm (4 feet) or 1500 mm (5 feet) respectively, as defined in harmonised standards.

Compact Fluorescent lamps (CFL)

Compact fluorescent lamps, often called energy-saving lamps, use thinner tubes that come in a spiral-like shape or as a series of short adjacent U-shaped tubes. They have sizes comparable to the classical filament light bulbs and aim to replace them. The efficacy of CFLs ranges from 50-70 lm/W: 3 to 5 times higher than filament lamps. Lifetimes are around 10 000 hours: 5 to 10 times longer than filament lamps. There are CFLs with integrated ballast (CFLi) that are mainly used in households and those without integrated ballast (CFLni) that are typically used in offices. Compared to filament lamps, CFLs have a warm-up time before they reach their rated light output and their colour rendering characteristics are worse. For these reasons they have been less popular as substitutes for GLS-lamps than expected around 2009 when the first lighting regulations were made.

High-Intensity Discharge lamps (HID)

HID-lamps create an electric discharge arc between two electrodes in a quartz or ceramic tube-like enclosure that contains a gas and metal salts. The compositions of the latter can be varied to obtain different characteristics: e.g. intensity, colour, efficiency, lifetime. Compared to other technologies, HID lamps provide the highest light intensity in a compact space. The main application is in street lighting. The older, less efficient high-pressure mercury lamps (HPM) can no longer be sold since 2015, under the existing regulations. Other types include high-pressure sodium (HPS), which often has a characteristic orange light and an efficacy of 90-140 lm/W, and the most recent metal-halide lamps (MH), that produce white light with an efficacy of 80-120 lm/W. Typical lifetimes range from 8 000 to 20 000 burning hours. Just like fluorescent lamps, HID-lamps need a ballast to start and maintain the electric arc. Most HID lamps do not have a good colour rendering and hence are not used for indoor lighting. Most HID lamps contain a small amount of mercury.

Light Emitting Diode lamps (LED)

The light emission by LEDs derives from electrons that fall back from a high-energy state to a low-energy state, emitting the difference in energy as a photon (a small quantity of light). This emission occurs in a solid material consisting of very thin (microns), suitable (p-n) layers of (doped) semi-conductor materials when an electric current is passed in the correct direction. This technology is therefore also referred to as ‘solid state lighting (SSL)’.

There are many variations of the (still evolving) technology, offering a large variety of lighting characteristics. The vast majority of LEDs used for general lighting purposes today uses blue-light-emitting semi-conductor materials, and a phosphor coating to convert this blue light into white (similar to what is done in fluorescent lamps). This technology now (2015) allows efficacies from 80 to 140 lm/W in commercial products, with over 200 lm/W already demonstrated in prototypes. An alternative is to use separate red, blue and green (RGB) LEDs and to mix their lights to obtain white (allows creation of lamps with colour-change ability). This technology is expected to provide the highest efficacies in future, up to 250 lm/W in 2030.

LED lamps only work under a controlled direct current (not alternating) and therefore need a control gear, that can be integrated in the lamp or separate. Amongst other functions, this control gear also determines the dimmability of the LED light source.

LEDs and OLEDs

In this Impact Assessment, the term LED will be used to indicate a light emitting diode based on inorganic materials, which is the vast majority of LEDs used for general lighting purposes today. LEDs based on organic materials are called organic LEDs or OLEDs.

Ballasts, Control Gears and Drivers (CG)

Fluorescent lamps, HID-lamps and LED-lamps all need a ballast or control gear or driver between the utility grid (mains, 230 V, 50 Hz, AC) and the light source to create the proper operating conditions. This CG may or may not be integrated in the lamp. Traditionally, ballasts were electro-magnetic with typical efficiencies around 80%. Modern ballasts for LFLs are electronic with efficiencies over 90%. In addition their high-frequency operation mode can also increase the efficacy of the light source itself. The current lighting regulations already push towards the use of electronic control gears.

Non-directional (NDLS) and Directional (DLS)

Lamps can emit their light all around (non-directional) or more concentrated in a certain direction (spot- or accent-lighting; directional). The current EU regulations make a distinction between NDLS and DLS lamps. A lamp is considered directional if 80% or more of its total light output is emitted within a cone with angle of 120˚. Currently, the light output (lumen) of a DLS lamp is measured in a 90˚ or 120˚ cone; the light output of a NDLS lamp is measured over the full 360˚. DLS lamps typically have a lower efficacy than NDLS lamps of the same input power and consequently minimum efficiency requirements in the current regulations are lower for DLS lamps. For LED-lamps, that have as much problems as being non-directional as directional, the need to distinguish between NDLS and DLS lamps is less obvious (except for small beam angles, see below).

Beam Angle

The light emission of a lamp does not have the same intensity in all directions. Typically the highest intensity is found on the centreline of the lamp. Looking at the lamp along another line, the intensity is lower. The angle between the centreline and the other line where the intensity is half (50%) of the maximum intensity is called the Beam Angle. Lamps with very small Beam Angles (below 20˚, very concentrated light) tend to have lower efficacies. Therefore some stakeholders have argued that the Beam Angle should be taken into account when prescribing minimum efficiency requirements.

Colour Rendering Index (CRI)

The CRI intends to express the ability of the light to faithfully render the real colours of an object. The CRI is currently measured by testing the rendering of 8 standard colours (Ra8). Filament lamps have a CRI=100, which is the maximum (best colour rendering). Other lamp types typically have lower CRI values. For indoor use and general task lighting the current regulations require a CRI of at least 80. Special tasks may require light with a higher CRI. Non-filament lamps (fluorescent, HID, LED) with higher CRI (between 80 and 95) are available but typically have lower efficacy. Therefore the CRI is taken into account when prescribing minimum efficiency requirements.

It is quite commonly accepted that the CRI is not the ideal measure to express colour rendering characteristics. In several cases, in particular for LED lamps, the CRI value does not correspond to how humans perceive the colour rendering. Alternative colour rendering scales have been studied for many years at the level of global standards (CIE) but no consensus has been reached and thus the CRI is still the only alternative.

Colour Temperature (CCT)

The regulations deal with lamps emitting white light, but this still covers several grades, ranging from yellowish warm-white to bluish cold-white. The grade of white is expressed by its (Correlated) Colour Temperature (CCT), which is the temperature of a black body that emits the same type of white light. Confusingly, lower CCTs (e.g. 2700-3000 K) indicate warm-white and higher CCTs (e.g. 5000-6500 K) indicate cold-white. In particular for LEDs, warm-white light sources have lower efficacies than cold-white ones. Therefore some stakeholders have argued that the CCT should be taken into account when prescribing the minimum efficiency requirements.

Lifetime and Lumen deterioration

Filament lamps at a certain moment just fail, i.e. they don’t emit any light anymore. This clearly defines their lifetime. For fluorescent lamps, HID-lamps and LED-lamps the useful lifetime is less clear. These lamps all exhibit a lumen-deterioration, i.e. the amount of light they emit decreases with time. In these cases the lifetime is typically defined as the time over which the amount of light decreases to 70% or 80% of its initial value.

:   [(1)](#footnoteref1)

     
       Data from MELISA model, Impact Assessment study 2018. Business sector revenues are derived from acquisition costs using the sector shares reported in Annex 4 section 3.1.
:   [(2)](#footnoteref2)
     Jobs are derived from sector revenues using an average turnover per employee:Industry:
       
       
       20 jobs / mEUR revenue, EUR 50 000 / employee  (1/3 manufacturing, 1/3 OEM, 1/3 services)Wholesale:
       
       4 jobs / mEUR revenue, EUR 250 000 / employeeRetail:
       
       
       
       16.7 jobs / mEUR revenue, EUR 60 000 / employeeInstallation:
       
       10 jobs / mEUR revenue, EUR 100 000 / employeeMaintenance:
       10 jobs / mEUR revenue, EUR 100 000 / employee
:   [(3)](#footnoteref3)

     
       The company is now separate from former mother-company Philips and is quoted on the stock exchange. Its name will soon change to ‘Signify’, to reflect the separation from Philips.
:   [(4)](#footnoteref4)

     
       Non-American parts of GE have been bought by a Hungarian company in 2018. GE is also selling the rest of its lighting business.
:   [(5)](#footnoteref5)

    Revenues and employment figures relate to light sources. They do not include the production, sales and installation of luminaires, nor the design and installation of lighting systems in the non-residential sector. In the current regulation, the luminaire manufacturers are in scope of Energy labelling only.
:   [(6)](#footnoteref6)

    "IKEA to sell only energy-saving LED lightbulbs" - The Guardian, August 2015
:   [(7)](#footnoteref7)

     
       Annual detailed enterprise statistics for industry (NACE Rev. 2, B-E) [sbs\_na\_ind\_r2], extracted 26.04.2018, 
    <http://appsso.eurostat.ec.europa.eu/nui/show.do>
:   [(8)](#footnoteref8)

    Eurostat, ProdCom, DS-056120-Sold production, exports and imports
:   [(9)](#footnoteref9)

    Preparatory Study on Light Sources for Ecodesign and/or Energy Labelling Requirements (‘Lot 8/9/19’), Final Report, Tasks 2 Annex C, VHK for the European Commission, October 2015. 
    <http://ecodesign-lightsources.eu/documents>
:   [(10)](#footnoteref10)

     
       Revenues from LED lighting are 30-40% of total revenues according to 2014 data from Philips and Osram.
:   [(11)](#footnoteref11)

     
       Jobs lost to external contractors (repair and maintenance, catering, manufacturing of machines), to external component suppliers, upstream suppliers of raw materials, etc.
:   [(12)](#footnoteref12)

    <http://www.philips.com/corporate/resources/annualresults/2015/PhilipsFullAnnualReport2015_English.pdf>
:   [(13)](#footnoteref13)

     
       EMEA: Europe, Russia, Middle-East and Africa
:   [(14)](#footnoteref14)

    - Light Sources & Electronics: LED, eco-halogen, (compact) fluorescent, high-intensity discharge, incandescent, electronic and electromagnetic gear, modules and drivers.

       - Consumer Luminaires: functional, decorative, lifestyle, scene-setting luminaires.

       - Professional lighting solutions: controls and luminaires for city beautification, road lighting, sports lighting, office lighting, shop/hospitality lighting, industry lighting
:   [(15)](#footnoteref15)

     
    <http://www.eurofound.europa.eu/observatories/emcc/erm/factsheets/philips-lighting-poland>
:   [(16)](#footnoteref16)

     
    <http://www.osram-group.com/~/media/Files/O/Osram/documents/en/fiscal-year-2015/osram-annual-report-screen.pdf>
:   [(17)](#footnoteref17)

    - SP: Main business automotive lighting (traditional, LED, OLED, laser). Other focus for cinemas, studios, stage lighting. Since 2015 includes OLED. SP is market leader in automotive with competitors Lumileds, Hella, Koito and Stanley Electrics. Main competitor for non-automotive speciality lighting is Ushio.

       - OS: LEDs emitting visible light, other opto-semiconductors emitting non-visible light or receiving incoming light and converting into signals. Main demand from automotive, communications, industry. Competitors: Nichia, Lumileds, Cree and Asian companies as Samsung, Epistar, Everlight, LG Innotek, Seoul Semiconductor, Lite-On, Toyoda Gosei.

       - DS: LED light engines (=LED module+control gear), electronic ballasts for LED and traditional, light management systems. Main competitors are Philips, Zumtobel, Lutron, and Asian manufacturers as Toshiba, Panasonic, Samsung, LG, Delta Electronics. In addition large number of product specialized manufacturers.

       - LS: production and sale of luminaires; design and implementation of solutions for internal and external lighting; lighting service business. Focus on street lighting, architectural design, professional interior lighting. Highly fragmented market: 5 leading providers have 30% of market. Main competitors in EU: Zumtobel, Philips, Fagerhult, Trilux, Schreder, Eglo Leuchten.

       - LP: General lighting lamp business, both traditional offerings and LED retrofit lamps. Three leading companies Philips, Osram and General Electric have market share over 50%. Regarding LED retrofit, these 3 leaders are joined by large number of medium-sized and small producers, including low-cost suppliers from Asia.
:   [(18)](#footnoteref18)

    An article in ‘Die Welt’ of March 2012, reports 41 000 employees for Osram worldwide and 10 100 in Germany. This is based on 2011 company information. 
    <http://www.welt.de/wirtschaft/article13915827/Fuer-tausende-Osram-Mitarbeiter-geht-das-Licht-aus.html>
:   [(19)](#footnoteref19)

    <http://www.welt.de/wirtschaft/article13915827/Fuer-tausende-Osram-Mitarbeiter-geht-das-Licht-aus.html>
    [,](, ) 
    <http://www.augsburger-allgemeine.de/augsburg/Osram-streicht-mehr-als-800-Stellen-Werk-Schwabmuenchen-auf-der-Kippe-id31374162.html>
    [,](, ) 
    <http://www.br.de/nachrichten/schwaben/inhalt/osram-schwaben-sparprogramm-100.html>
:   [(20)](#footnoteref20)

    <http://www.reuters.com/article/us-philips-osram-licht-divestments-idUSKBN0UM1W020160108>
    [,](, ) 
    <http://www.produktion.de/nachrichten/unternehmen-maerkte/osram-will-chiphersteller-werden-277.html>
:   [(21)](#footnoteref21)

    <http://www.focus-fen.net/news/2016/03/23/401325/bulgaria-economy-minister-attended-groundbreaking-ceremony-for-osram-factory-roundup.html>
:   [(22)](#footnoteref22)

    <http://ww.plusden.sk/regiony/zapadne-slovensko/najprv-vyhadzov-teraz-nabor-novozamocka-firma-chce-zamestnavat.html>
    [,](, ) 
    <http://www.nitralive.sk/vystavba/budovy/24456-osram-planuje-v-nitre-postavit-novy-zavod>
:   [(23)](#footnoteref23)

     
       General Electric Annual Report 2015, 
    <http://www.ge.com/ar2015/assets/pdf/GE_AR15.pdf>
:   [(24)](#footnoteref24)

     
       Exchange rate of 28/04/2016: 1 dollar = 0.88 euros
:   [(25)](#footnoteref25)

     
       1 Crore Rupees = 10 million rupees = 151 000 US dollars = 132 880 EUR(April 2016).
:   [(26)](#footnoteref26)

     
       The Lot 8/9/19 study assumed as industry jobs 1/3 manufacturing, 1/3 OEM and 1/3 services.
:   [(27)](#footnoteref27)
     ‘Solid-State Lighting, 2017 Suggested Research Topics Supplement: Technology and Market Context’, US Department of Energy, September 2017
:   [(28)](#footnoteref28)

     
    [Directive 2005/32/EC of the European Parliament and of the Council of 6 July 2005 establishing a framework for the setting of ecodesign requirements for energy-using products and amending Council Directive 92/42/EEC and Directives 96/57/EC and 2000/55/EC of the European Parliament and of the Council](http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32005L0032)
    . OJ L 191, 22.7.2005
:   [(29)](#footnoteref29)

     
    [Communication from the Commission to the Council and the European Parliament - Establishment of the working plan for 2009-2011 under the Ecodesign Directive. COM/2008/0660 final. 21 October 2008](http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A52008DC0660)
    . (Ecodesign Working Plan 2009-2011)
:   [(30)](#footnoteref30)

     
    [Commission Staff Working Document Establishment of the Working plan 2012-2014 under the Ecodesign Directive - SWD(2012)434/F1](http://ec.europa.eu/transparency/regdoc/?fuseaction=list&coteId=10102&year=2012&number=434&language=en)
     (Ecodesign Working Plan 2012-2014)
:   [(31)](#footnoteref31)

    This objection was defeated in ENVI committee by 43 votes against and 4 in favour.
:   [(32)](#footnoteref32)

    The motivation of the objection was that the EP wanted to delay the discussion of the draft labelling measure so that it would have to become a delegated act under the recast post-Lisbon Energy Labelling Directive in 2010. The measure was indeed subsequently adopted as a delegated act.
:   [(33)](#footnoteref33)

     
    [Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out the requirements for accreditation and market surveillance relating to the marketing of products and repealing Regulation (EEC) No 339/93](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521025655801&uri=CELEX:32008R0765)
    . OJ L 218, 13.8.2008, p. 30
:   [(34)](#footnoteref34)

     
    [Commission Regulation (EC) No 278/2009 of 6 April 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for no-load condition electric power consumption and average active efficiency of external power supplies](file://C:\Users\Leo\AppData\Local\Microsoft\Windows\INetCache\Content.Outlook\4N1U3PU4\Commission%20Regulation%20(EC)%20No%20278\2009%20of%206%20April%202009%20implementing%20Directive%202005\32\EC%20of%20the%20European%20Parliament%20and%20of%20the%20Council%20with%20regard%20to%20ecodesign%20requirements%20for%20no-load%20condition%20electric%20power%20consumption%20and%20average%20active%20efficiency%20of%20external%20power%20supplies)
    , OJ L 93, 7.4.2009
:   [(35)](#footnoteref35)

     
    [Commission Regulation (EC) No 640/2009 of 22 July 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for electric motors.](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521190386242&uri=CELEX:32009R0640)
     OJ L 191, 23.7.2009
:   [(36)](#footnoteref36)

     
    [Commission Regulation (EC) No 641/2009 of 22 July 2009 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for glandless standalone circulators and glandless circulators integrated in products](http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R0641)
    . OJ L 191, 23.7.2009, p. 35.
:   [(37)](#footnoteref37)

     
    [Commission Regulation (EU) No 327/2011 of 30 March 2011 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for fans driven by motors with an electric input power between 125 W and 500 kW](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521190501499&uri=CELEX:32011R0327)
    . OJ L 90, 6.4.2011, p. 8.
:   [(38)](#footnoteref38)

     
    [Commission Regulation (EU) No 547/2012 of 25 June 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for water pumps](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521190697262&uri=CELEX:32012R0547)
    . OJ L 165, 26.6.2012, p. 28
:   [(39)](#footnoteref39)

     
    [Commission Regulation (EC) No 1275/2008 of 17 December 2008 implementing Directive 2005/32/EC of the European Parliament and of the Council with regard to ecodesign requirements for standby and off mode electric power consumption of electrical and electronic household and office equipment](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521191695475&uri=CELEX:32008R1275)
    . OJ L 339, 18.12.2008, p. 45.
:   [(40)](#footnoteref40)

     
    [Commission Regulation (EU) No 801/2013 of 22 August 2013 amending Regulation (EC) No 1275/2008 with regard to ecodesign requirements for standby, off mode electric power consumption of electrical and electronic household and office equipment, and amending Regulation (EC) No 642/2009 with regard to ecodesign requirements for televisions](http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1521191873275&uri=CELEX:32013R0801)
    . OJ L 225, 23.8.2013, p. 1.
:   [(41)](#footnoteref41)

     
    [Directive 2014/35/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the Member States relating to the making available on the market of electrical equipment designed for use within certain voltage limits](http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035)
    . OJ L 96, 29.3.2014, p. 357. (LVD)
:   [(42)](#footnoteref42)

     
    [Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances in electrical and electronic equipment](http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0065)
    . OJ L 174, 1.7.2011, p. 88. (RoHS Directive)
:   [(43)](#footnoteref43)

     
    [Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC.](http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006R1907)
     OJ L 396, 30.12.2006, p. 1–849 (REACH Regulation)
:   [(44)](#footnoteref44)

     
    [Directive 2014/30/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the Member States relating to electromagnetic compatibility](http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0030)
    . OJ L 96, 29.3.2014, p. 79 (EMC Directive)
:   [(45)](#footnoteref45)

    European Commission Conference on Product Policy –Ecodesign & Energy Labelling, 20-21 Feb. 2014, misc. lectures.
:   [(46)](#footnoteref46)
     
    <https://ec.europa.eu/info/law/law-making-process/better-regulation-why-and-how_en>
:   [(47)](#footnoteref47)
     For details, see a separate note and Excel file, ‘Development BAU2008 scenario for Light Sources v20170124’ (internal note VHK, 2017)
:   [(48)](#footnoteref48)

    Material-efficiency Ecodesign Report and Module to the Methodology for the Ecodesign of Energy-related Products (MEErP) PART 1: MATERIAL EFFICIENCY FOR ECODESIGN - Final report to the European Commission - DG Enterprise and Industry 5 December 2013.

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