The EU-27 are currently in the process of phasing-out domestic consumption of fluorescent lighting. There are two regulations – one final and one draft – that will eliminate fluorescent lighting by 2023:

• Ecodesign Directive: Commission Regulation (EU) 2019/2020.
• Restriction of Hazardous Substances (RoHS) Directive: RoHS is completing its Parliamentary and Council scrutiny period in the coming few months.

Despite ambitious domestic policy to ban inefficient, mercury-containing lighting products, these internal market policy decisions stand in stark contrast to the position the EU-27 took in their proposal to amend lighting products in the Minamata Convention on Mercury. Through the Convention, the EU only proposed to phase-out halophosphate fluorescent lamps – a technology the EU banned in 2011. It is important to note that the Ecodesign and RoHS Directive regulations only apply to the EU’s internal market and thus do not affect exports; however a ban to these same products under Minamata would eliminate exports of those fluorescent lamps.

Europe has two manufacturing facilities for fluorescent lamps which are currently operational – one in Poland and one in Germany. The fluorescent production lines at these lighting factories are limited because the product they produce is no longer fit for purpose. EU domestic market for fluorescents will be gone in 2023 and regional export markets to the European Economic Area, the United States and other countries is also being phased out by separate legislation.

To be viable, converting the facilities in Poland and Germany from T8 and T5 linear fluorescent lamps to T8 and T5 LED retrofit tubes will require EU government investment. This study demonstrates that the fluorescent export market from these countries is already in decline and projected to reach zero around 2025. However, through the EU Taxonomy Fund, there is potential to invest in these facilities and create a long-term, domestic supply of high-quality LED tubes in Europe, produced in Poland and Germany.

This report highlights this opportunity for a Taxonomy Fund investment in EU manufacturing of energy- efficient, high-value-add LED tube manufacturing, which will result in significant employment and climate benefits.

The EEB and CLASP applaud the European Commission for adopting proposals that will phase out all general purpose compact and linear fluorescent lamps (CFL and LFL) containing mercury in the coming two years.

Currently, the EU regulates mercury in light bulbs through the Restriction of Hazardous Substances (RoHS) Directive, by allowing mercury use in lighting via an exemption list. CFLs and LFLs have been tolerated so far because of the once limited availability of mercury-free alternatives.

For years the EEB, CLASP, Member States and experts have tirelessly campaigned to end mercury lamps, as there are more efficient, mercury-free Light Emitting Diodes (LEDs) widely available on European markets, making fluorescent lamps redundant. In 2019, a study by CLASP and the Swedish Energy Council proved that “91-93% of fluorescent light fixtures in Europe can accept LED retrofits“.

Mercury is a well-documented neurotoxin that causes adverse effects to the developing brain, cardiovascular system, kidneys, and thyroid glands. The World Health Organisation puts mercury in the top ten most problematic chemicals for public health.

The European Commission could have by law removed inefficient and toxic fluorescent lamps from sale as far back as 2018, when its own experts confirmed the legal criteria for a market ban under RoHS were fulfilled. Their availability until the end 2023 is estimated to cost bill-payers over €16.8 million per day in lost efficiency savings for the next 2 years, according to recent NGO estimates.

Michael Scholand, Senior Advisor with CLASP Europe, said, “While the Commission’s decision has been delayed several years, the savings from this measure are still significant and will benefit EU citizens and businesses. Between 2023 and 2035, we calculate a net savings to the EU of €18.2 billion, as well as avoiding 1.8 metric tonnes of mercury from the fluorescent lamps. Furthermore, over 190 TWh of electricity will be saved, avoiding 55 million metric tonnes of CO₂ and contributing to the EU’s COP26 CO₂ reduction targets.”

Elena Lymberidi-Settimo, Policy Manager at the EEB for the Zero Mercury Campaign said, “The European Parliament must now follow through this big step forward and allow rapid final adoption of a ban on these mercury inefficient lamps. At the same time, the EU should follow its commitments set out in the European Green Deal, Chemicals Strategy for Sustainability and Zero Pollution Action Plan and support the African region’s proposal at the next session of the Minamata Convention’s Conference of the Parties in March 2022, to prohibit the manufacture and export of most fluorescent lights by 2025.”

To the regret of NGOs, progress towards phasing out other mercury added lamps, such as high-pressure sodium (orange streetlights) and metal halide lamps, has not yet been made. The amendments to the RoHS Directive will still allow these mercury-containing lamps to remain on the market for the next 3-5 years at a minimum.

Read the article on EEB.org

Brazil’s INMETRO is currently considering modifications to the National Label for Energy Conservation (ENCE) for refrigerators to better differentiate more efficient products that will lower electricity consumption, save consumers money, and reduce carbon dioxide emissions. The modifications being considered include the addition of “A+,” “A++,” and “A+++,” to the current A to G scale, since all refrigerators currently found in the market are already “A” class. These modifications are similar to the additional categories that were added to the European Union’s energy efficiency label in 2010, and then removed beginning in 2017. The Electricity Generation Authority of Thailand (EGAT) has also experimented with the creation of additional categories on their EGAT No. 5 label, which previously categorized products on a scale from level 1 to level 5. They did this by adding three stars to their label, so that the top labeling class changed from “level 5” to “level 5 with three stars.” The experiences from both the European Union (EU) and Thailand demonstrate that, while creating such additional categories can help to differentiate products, it can also decrease the effectiveness of the label and confuse consumers.

Key Findings and Recommendations:

• Creating additional label categories is not as effective at motivating consumer choice as a full revision of the energy efficiency criteria for the existing label. In the EU, consumers were less likely to pay more for an “A+++” product over an “A” product than for an “A” product over a “D” product. In Thailand, 94% of consumers would not purchase a product that does not achieve the level 5, but only 11% of consumers would pay 20% more for a No. 5 product with three stars over a No. 5 product with no stars.
• Additional label categories can confuse consumers. In Thailand, 57% of retailers reported that consumers asked for clarifications about the meaning of the additional stars on the existing No.5 label. In the EU, Electrolux, a major appliance manufacturer, publicly criticized the European Commission for the additional categories as “increasingly confusing to consumers,” creating additional momentum for the elimination of the categories starting in 2017.
• INMETRO should implement a full rescaling instead of creating additional labeling categories. This would achieve the objective of differentiating products, maintain the motivating power of the top labeling class, and avoid confusing consumers.
• If additional categories are created, a comprehensive consumer awareness campaign should be launched to educate consumers on the value of the new categories, and that the “A” class represents the least efficient refrigerator class currently allowed on the market. Displaying the “A” class as the lowest efficiency class on the label would help to make this clear. In addition, a consumer awareness campaign, including materials for retailers illustrating how to explain the new classes to consumers, would reduce confusion.

Global television sales continue to grow as product prices steadily decline, and TVs now account for an estimated 3% to 8% of global residential energy use. Improving the energy efficiency of TVs becomes increasingly important against this backdrop, in order to offset the potential energy and environmental impacts of continued growth in television sales. TV supply chains are global in nature, however, and global action around TV efficiency is hindered by competing national and regional policies governing TV energy use. Efforts to facilitate improvement in TV efficiency worldwide would therefore benefit from the establishment of a level international playing field around TV energy performance requirements and associated test methods.

A new study by the SEAD Initiative seeks to advance international harmonization of TV energy efficiency policies by analysing the test methods and performance requirements currently in use around the world, identifying opportunities for achieving greater international policy alignment. This study was carried out in support of the Asia-Pacific Economic Cooperation (APEC)Collaborative Assessment of Standards and Testing Methods (CAST), with specific focus on SEAD and APEC economies, including Australia, China, the European Union, India, Japan, Korea, the Philippines, the United States, and Vietnam.

Test Methods

This report examines a total of 6 test methods for TVs, finding that the largest differences between test methodologies exist among the largest markets most active in policy development (i.e. the EU, the US, and China). The study finds that two standards are most relevant to international harmonization efforts—the International Electrochemical Commission (IEC) 62087 method and China’s GB 24850-2013 method—and that greater harmonization between these testing approaches is essential to allowing future comparisons between products in China and other regions.

Other key findings related to TV test methodology include:

• TV test methods need to constantly evolve due to the rapid rate of TV technology development, to ensure that testing results are representative of actual in-home energy consumption.
• Sample preparation is key. Sample preparation (i.e. the way that TV settings are configured in preparation for testing) is the biggest disruptive influence that limits that comparability of energy test results across countries.
• Some policy requirements add testing divergence. Key areas of policy that are related to testing and would benefit from greater harmonization include: i) illuminance levels used for testing a TV’s Automatic Brightness Control (ABC) feature, ii) incentives for ABC testing, and iii) approaches to peak luminance levels.

Energy Performance Requirements

TV energy efficiency policies from 13 regions are analyzed, totaling over 70 different energy performance thresholds. Despite televisions everywhere being very similar in technology, this analysis reveals considerable global variation in TV energy efficiency policy. Several underlying reasons for these differences are identified, including:

• resource constraints among policymaking bodies;
• limited availability of market assessments to support policymaking;
• regional politics;
• unaligned policy schedules or policy revision cycles; and
• concerns that more stringent policies might negatively impact product availability and cost.

To advance greater policy harmonization around energy performance requirements for TVs, this study proposes a series of benchmark performance levels, which policymakers can use as a foundation for setting their own local policies and label schemes. In addition, this study recommends a number of resources that could assist policymakers to achieve cost effective efficiency improvements in TVs, including:

• Information on policy cost and potential savings, to support a shift toward the highest energy efficiency level that is feasible but not expected to occur in the absence of further policy action; and
• Steps for applying this study’s benchmark performance levels in their region, supported by the provision of electronic tools and training.

Despite the variation in energy performance requirements and test methodologies identified in this study, the authors none-the-less conclude that global harmonization of test methodologies, and even performance levels, could be made a reality within a few years.

This study was written by Stephen Fernandes, Catriona McAlister, Anson Wu, and Robert Harrison of Intertek Plc; Jeremy Tait of Tait Consulting; Keith Jones of Digital CEnergy Australia; and Anette Michel from Top Ten Europe. The project was funded by the Australian Government, with support from the SEAD initiative and CLASP.

Policy Situation

In September 2016, the final stage of 244/2009 (“Stage 6”) is scheduled take effect and phase out D-class mains-voltage halogen lamps, in favour of B-class halogen lamps and more efficient technologies such as CFLs and LED lamps (which are A, A+ and A++).[1]

The Lighting industry approached the European Commission with a request to delay the effective date of Stage 6 to 2020. The Commission conducted a review study and stakeholder consultation and responded by proposing a two year delay (to September 2018). [2]

However, market research and product testing of LED lamps shows that the technology has improved so much in the last two years that the technical and economic need for a delay to the policy measure is no longer necessary, as summarised by the following:

1. Consumer Benefits: LED technology development has been incredibly fast, particularly in the last 2 years. LED lamps are available now which offer consumers payback periods of <1 year when operated 3 hours a day.[3] These payback periods will become even shorter in the coming years LEDs continue to progress, and by keeping the 2016 date, innovation in LED lighting with be further accelerated with a faster price reduction from the high sales volumes benefitting consumers sooner than if Stage 6 was delayed. LED lamps can offer consumers a long lifetime, high colour rendering, significant energy savings and a familiar shape and appearance. In the UK, a household that switches today can save £100 per socket over the 15,000 hour life of an LED lamp in avoided replacement halogen lamps and saved electricity.[4] Retailers like IKEA are recognising this benefits for their customers and have announced they will switch to all LED by 2016.[5]
2. New Jobs: As LED businesses grow, new jobs are being created across Europe that focus on LED lighting. In addition to the new direct-employment jobs, there are indirect job benefits as well. Saving households’ money on their energy bills increases the disposable income available to spend elsewhere in the economy. For example, scaling the Europe-wide estimated savings from not delaying Stage 6 to the UK economy translates into the creation of approximately 1090 new permanent jobs in other sectors of the economy. [6]
3. Energy Security: Europe is not on target for 2020 efficiency gains[7] – in part because the lighting regulation 244/2009 hasn’t delivered the expected savings due to the high sales of halogen. Energy-efficiency is a resource that can be used to reduce dependence on energy imports, providing greater energy security for Europe. LED lamps are available today that are already 8 times more efficient than halogen and 2 times more efficient than compact fluorescent lamps. LED lamps typically save 85% of energy compared to halogen lamps.
4. Policy Precedent: the modification of an existing law in response to industry pressure sets a dangerous precedent for all ecodesign policies. There was a different view from industry when this law was adopted in 2009 and the industry association declared its support: “We welcome the draft EU decision aiming at restricting incandescent lamps in Europe by 2012 and low efficiency halogen lamps by 2016. […] The agreed phase-out timeline gives enough time for restructuring about 14 factories and ensuring industry competitiveness.” [8]
5. Policy Analysis: The Commission was required to conduct a review of Stage 6, and Recital 20 in the regulation (EC No 244/2009) provides guidance: “(20) A review of this measure should take particular note of … the development of new technologies such as LEDs and of the feasibility of establishing energy efficiency requirements at the ‘A’ class level.” However the review resulted in a proposal for a 2-year delay to Stage 6 rather than establishment (or not) of the A-class level. Stage 6 is currently set at B-class halogen lamps, which are available to purchase in Europe and can be out-sourced in bulk from at least one lamp manufacturer in China.[9] A recent study found that if B-class lamps were to enter the European market in volume, they will undermine LED and eliminate approximately half of the anticipated energy savings for consumers.[10]

To learn more, read CLASP’s latest analysis, produced in collaboration with the Danish Energy Agency and Energy Piano: European LED Market Evolution and Policy Impacts.

[1] Ecodesign regulation EC No 244/2009 split the European incandescent lighting market into two groups: frosted lamps and clear lamps, with different energy-efficiency requirements for each. The policy measure for frosted incandescent lamps intended that they be replaced by compact fluorescent lamps (CFLs, which are A-class). Clear incandescent lamps were to be replaced by mains-voltage halogen lamps (D-class energy label). These measures were introduced – some of them gradually – over a series of five regulatory Stages between 2009 and 2013. Although frosted lamps constituted 75% of sales in 2009, most frosted sockets switched to halogen instead of CFL.

[2] 5 November 2014, Commission issued an email which stated the following: EU TBT notification concerning the Draft Commission Regulation amending Regulation (EC) No 244/2009 has now been published on the WTO website under the following reference: G/TBT/N/EU/248.

[3] Philips offers an LED lamp for €6.95 which can replace a 60W incandescent (or 52W halogen) lamp but only consumes 9 Watts. Used 3 hours/day at the average EU household electricity price of €0.20/kWh, the payback period compared to at 52W halogen is 9 months. As prices for LED lamps continue to come down, the payback will get even shorter between now and September 2016.

[4] Comparison of £8 LED lamp 9 Watts (800 lumens) 15,000 hour life replacing a £2 halogen lamp 52 Watt and 2000 hour life, 14 pence/kWh. Savings of £99.40 in lamps and electricity.

[5] IKEA announced that customers will only be able to buy LED lamps by 2016, and they intend to install large numbers of LED lamps in their stores and warehouses. Click here for the article.

[6] Savings of €6.6 billion Euros from 2016 to 2026; divide by 10 to get average annual savings of €660 million. Apportion those savings by population (UK is 12.7% of EU) to estimate €83.8 million for the UK. According to ECOFYS, there are 13 permanent jobs created for every €1 million in annual energy savings. Multiplying €83.8 by 13 = 1090 new permanent jobs for the UK from not delaying Stage 6.

[7] “Gap to 2020 energy efficiency target remains wide” ENDS Europe, 5 February 2015. Weblink to article.

[8] Questions & Answers on the EU decision to phase out incandescent and less energy efficient lamps, European Lamp Confederation (ELC), 18 March 2009.

[9] “European LED Market Evolution and Policy Impacts”, by Danish Energy Agency, Energy Piano and CLASP European Programme; 16 March 2015.

[10] Ibid.

In support of the European Commission’s ongoing review of existing energy efficiency policies for appliances, CLASP prepared two discussion papers. These represent an independent contribution to help inform development of the Ecodesign and Energy Labelling criteria for commercial refrigeration equipment under DG ENER Lot 12.

During 2014, the Commission prepared proposals for minimum efficiency requirements and energy labels for five types of commercial refrigeration equipment: supermarket segment refrigerated commercial display cabinets, beverage coolers, refrigerated vending machines, small ice-cream freezers, and soft scoop ice-cream cabinets. CLASP’s analysis focuses on the highest impact equipment from that overall scope, namely:

• Key types of supermarket display cabinets (vertical chilled and horizontal frozen);
• Beverage coolers; and
• Refrigerated vending machines

Our analysis is published in two separate reports. The first report, Analysis of EU Policy Proposals for DG ENER Lot 12 Commercial Refrigeration, examines how the proposed European thresholds for labels and minimum energy performance standards (MEPS) compare with policy thresholds for the same equipment in other parts of the world, as well as with real product performance data. This analysis will assist stakeholders in assessing the appropriateness of the level of stringency.

The second report, Analysis of Specific Issues Regarding EU Policy Proposals for DG ENER Lot 12 Commercial Refrigeration, presents the results of our investigation into priority aspects of evidence that are of interest to the Commission. These include:

• Benchmark figures for “best-in-world” MEPS to compare with EU proposals;
• Evidence about the difference in efficiency between integral and remote cabinets;
• How policies in other regions have attempted to minimize the testing burden on manufacturers, including “representative cabinets;”
• Ensuring more accurate, repeatable and reproducible test methods (reducing the potential for ‘gaming’);
• Information on likely impact on small and medium enterprises (SMEs);
• CLASP’s views on some aspects of the comments submitted to the Consultation Forum by the European Partnership for Energy and the Environment (EPEE) and Eurovent on September 1, 2014.

These reports were authored for CLASP by Jeremy Tait of Tait Consulting Limited, with support from Judith Evans of RT&D and Marie Baton of CLASP.

Lighting accounts for about 15% of global energy consumption and nearly 6% of greenhouse gas emissions. Linear fluorescent lighting (LFL) is one of the most popular lighting technologies used in the commercial, industrial and outdoor sectors. Around 3 billion LFLs are manufactured each year, which are responsible for producing around 58% of the world’s artificial light. Although LEDs may well be the “light source of the future,” LFLs still dominate the current landscape due to their efficacy, long lifetimes and cost-effectiveness.

Recognizing the importance of LFLs in overall lighting energy consumption, CLASP, Beletich Associates, Erik Page & Associates, and Ballarat Consulting initiated this LFL mapping and benchmarking analysis to assess market trends and perform international comparisons of policies in major economies around the world. The study lays the technical foundation for strong and comparable energy performance requirements at the global level, and to pull the market towards higher levels of product efficiency.

This study provides detailed market analysis of linear florescent lamps and ballasts in six economies that represent a significant proportion of the world market for LFLs: Australia, Canada, China, the European Union, India and the US. The economies studied already have well-harmonized test procedures for linear fluorescent lamps. Thus lamp metrics used in these economies can be compared directly, without the need for any conversion or normalization.

The study is divided into three components:

• S&L policy analysis: The S&L policy analysis component includes a review of existing S&L initiatives and characteristics for linear fluorescent lamps and ballasts in the selected economies.
• Market assessment: The market assessment component establishes LFL characteristics in different economies by comparing the market sizes and trends as well as the energy performance of products offered on the market.
• Lamp testing: The testing component compares and highlights energy performance differences of LFLs in various economies. A small number of lamps from China, Europe (UK), India and the US were sampled and tested in order to derive insights into the performance of commonly available lamps in large economies.

In most economies, water heating appliances are some of the most energy-consuming, and typically account for 15% to 25% of energy in the residential sector. Globally, heating water in the residential sector may use as much as 11 petajoules per year.

CLASP conducts product and policy benchmarking studies to inform policymakers about opportunities to raise the ambition of national policies in order to maximize energy savings and CO2 emissions reductions.  Benchmarking policies and products is challenging due to incomparability of products and standards in different parts of the world, different approaches to performance testing, and lack of or unavailability of critical data.

Particularly, water heaters are one of the most complex product categories due to a large variety of product types, technologies, and fuels used for heating water. Traditionally, energy efficiency standards and labels have set performance requirements for water heaters by type (e.g., storage electric water heater, gas instantaneous water heater, etc.), thus inhibiting the comparison across water heater technology classes.

To address this challenge, CLASP and Waide Strategic Efficiency conducted a preliminary analysis on water heaters to identify future research needs that will lead to the successful benchmarking of policy settings for this product category, and will thereby support policymakers in better understanding their options to improve water heater energy efficiency.

The study provides an overview of various water heating technologies, test methods, and energy efficiency of residential water heaters in eight economies, including in Australia, Brazil, Canada, China, European Union, India, Korea, and the US.

The study is divided into the following three main components:

Task 1 – product definition

• Definition of relevant product classes or categories, discussed in section 2
• Listing and assessment of country data sources i.e. a listing of test procedures and regulations, presented in sections 3-10 by economy.

Task 2 – mapping 

• Mapping of product characteristics in selected countries, presented in section 11
• Mapping of existing standards and labelling initiatives and a description of their characteristics, presented in section 12
• Identification and initial comparison of test procedures, presented in section 13.

Task 3 – benchmarking 

• Identification of potential issues in test results comparison that would need to be addressed in a full benchmarking study, presented in section 14
• Analysis of knowledge gaps that need to be addressed in a full benchmarking study, discussed in section 15.

This paper proposes recommendations to policy makers based on a real time data collection exercise carried out in the UK, to analyze the “real world usage” of network connected devices. The paper also maps out how to replicate the project approach and methodology in the US and other regions, to determine whether similar opportunities exist in other areas.

Developing test procedures to measure the energy performance of products is fundamental to delivering the energy saving potential from setting energy performance standards and labeling requirements. And yet such test procedures are not always sufficiently well aligned, in time and in substance, with the policy requirement they are intended to support. In this paper the effectiveness of the EU approach to developing such standards is assessed and a portfolio of options for improving the alignment between test procedures and EU Ecodesign and Energy Labelling requirements are outlined. The intention of the paper is to help inform the discussion in Europe, for example in the context of the ongoing simultaneous review of the EU’s Ecodesign and Energy Labelling Directives during 2014 and 2015.

This paper was written for CLASP by Edouard Toulouse, an independent consultant and long time participant in the regulatory process in Europe.