Ban on incandescent light bulbs and legislation about CFLs in the EU

rikgheysens@hotmail.com

Ned

Historical survey of the introduction of the ban on incandescent lighting in the European Union

  1. The European Commission needs democratic control
  2. Detailed phase-out plan
  3. How got it so far with it?
  4. Negative impact on the functionality
  5. Health consequences
  6. How did the EU justify the ban on incandescent light bulbs?
  7. The question of the CO2 emission
  8. The share of lighting in the energy consumption
  9. The answer of the European Commission to my letter
  10. Some relevant passages from the European legislation

The European Commission employs about 23,000 permanent civil servants and 11,000 temporary or contract workers, (www.eurunion.org/eu/images/stories/lesson5.ppt) while an estimated 15-20,000 lobbyists attempt to win lawmakers to their client's point of view! (euobserver.com)

Latest news:

17 April 2015 in "ec.europa.eu" Phase-out of inefficient lamps postponed to 1 September 2018 "On 17 April 2015 Member States agreed to the Commission's proposal to postpone the phase-out of inefficient "D"-class halogen lamps by two years to 1 September 2018. The vote was preceded by a thorough review process open to the public, examining the best way forward. (...) By analysing the lighting market and technological developments, the Commission came to the conclusion that 1 September 2016 would be too early for LED technology to fully replace halogen lamps; a more appropriate phase-out would be 2018. Member States have now approved this two-year prolongation.

What changes exactly on 1 September 2018?

From 1 September 2018 onwards, some non-directional mains-voltage halogen lamps (mainly the pear-shaped ones) will no longer be brought to the market. This decision does not affect

  • directional halogen lamps, such as popular spotlights
  • halogen lamps often used in desk lamps and flood lights
The measures will not apply to products that are already on the shelves in stores, but only to new products being offered for sale.

Everyone agrees that a maximum of around 6,800 job losses in halogen lamp production are inevitable and will happen irrespective of any policy intervention due to the arrival of LEDs. (...) Deferring the phase-out to 1 September 2018 gives manufacturers the time to create replacement jobs in these areas, while supporting innovative companies in the EU providing novel lighting solutions based on LEDs."

23 March 2015 in "www.ledsmagazine.com" EC and European lighting industry clash on halogen ban (MAGAZINE)

1 December 2015 in "www.ledsmagazine.com" LightingEurope pushes to delay EC-mandated phase-out of eco halogen lamps "Furthermore, the organization [LightingEurope] said 200 million installed luminaires throughout Europe would become unusable if the current lighting regulations are enforced. Those outdated fixtures would have to be replaced with alternative luminaires valued at EUR 10 billion ($12.5 billion), according to LightingEurope."

Summary:

A precise definition of some concepts is given in "Preparatory Study on Light Sources for Ecodesign and/or Energy Labelling Requirements ('Lot 8/9/19')." Draft Interim Report, Task 3 (preliminary), December 2014 Also: Draft Interim Report, Task 1, Main Report, November 2014. [planning; documents]

  • The ban on halogen lamps should start - if the European Commission (EC) decides not otherwise - from September 2016 on. (Stage 6 of 244/2009)
  • The EC has worked on a proposal to delay the ban on halogen incandescent lighting for 2 years (September 2018 instead of September 2016).
  • In October 2013, LEDs Magazine published the article "Energy efficiency may come at the cost of consumer confidence". LightingEurope, the association representing lighting manufacturers and national lighting associations, stated that Stage 6 of 244/2009 has to be reconsidered and that 2019 would be a more realistic date for the ban of halogen lamps, rather than the deadline of 2016. The reasons are among others:
    • Affordability: LEDs are still too expensive compared with halogen lamps.
    • The quality of LEDs has to be improved. It would be detrimental to phase out halogen bulbs when only low-quality LEDs would be available in the lower price categories.
    • The benefits are not always obvious to the consumer when not frequently used rooms are equipped with LEDs.
  • 12 November 2013, adapted point of view: LightingEurope position on the review of the Stage 6 Requirements of Commission Regulation (EC) No 244/2009. The new position is among others the abolishment of Stage 6 requirements in order to prepare a viable alternative (i.e. appropriate LEDs) for the EU citizens, without compromising jobs.
  • 25 November 2013: The Ecodesign Consultation Forum was held in Brussels where a Commission Staff Working document was discussed. How the EC will conclude, will be know in the next couple of months.

November 18, 2013:

  • My report in reply to the Ecodesign Consultation Forum to be held in Brussels (25 November 2013).

1. The European Commission needs democratic control

December 18, 2012:

2. Detailed phase-out plan

Source: Consumption and Effiency Trends in European Union, p. 39.

Remarks:

  • LEDs are exempted from all functionality requirements. (FAQ Europe)
  • Minimum requirement for all lamps: E class. F and G lamps phased out (Same source)
  • By the end of 2012, the level will be made progressively stricter (to class C) for the other wattages too, completely phasing-out clear incandescent bulbs. (Consumption and Effiency Trends in European Union, p. 39)
  • Halogen clear lamps (xenon-filled) from energy class C will remain on the market until 2016. (Same source)

N.B.: The lamp energy label was introduced in 1998.

The energy label for lamps:

3. How got it so foar with it?

In this context, Winia Syp enumerates in the periodical Elsevier (August 15, 2009) the following steps.

  • On March 1, 2007, Philips succeeds to bring into line the European manufacturers of lamps in order to ban the incandescent lamp.
  • The CMO of Philips of that time, Geert van Kuyck, revealed in the Tijdschrift voor Marketing, that the Philips strategy about durability, climate and ban on incandescent lamps originated from his department. "The message of Philips that the incandescent bulb absorbs a large part of the electricity of the households, was a huge success." We underestimate what a really good marketing can do, namely, to produce enormous changes.
  • On December 8, 2008, the European ministers of Environment decided to phase out the incandescent bulb, to begin from September 1, 2009 on.
  • On March 18, 2009 the European Commission passed the Regulation 244/2009. As a consequence of it, all frosted incandescent lamps are banned from September 1, 2009. The clear lamps are phased out progressively from September 1, 2009 on and finishing at September 1, 2012. Directional lamps, such as spots, will be covered by a dedicated measure later on.
  • The author of the article in Elsevier asks why one had to ban the incandescent bulbs if the alternatives were so attractive. Harry Verhaar, senior director Energy & Climate Change says that the European heads of the governments had to pass the ban on incandescent lamps, because otherwise, they could not reach their own climate targets.
  • September 1, 2016: Also the production and import of the less efficient halogen lamps is banned in the European Union.

Film 'Giftiges Licht' van Alexandra Pfeil:

  • MEP Holger Kramer declared:"It is clear that the health aspects have not played a role in the ban on incandescent bulbs and the heavy marketing of energy saving lamps. The European Commission has admitted it openly. There were at that time no far-reaching investigations for it. It was not just about mercury, but also, for example, about the unpleasant effects of the light on the human psyche. (...) These decisions were heavily influenced by economic interests. The classic light bulbs cost just a few cents. The margins are higher in energy saving lamps. Therefore, there was also an economic interest, not only an environmental policy."
  • In one of these studies in 2009 (final report Lot 19: Domestic lighting, Contractor: VITO, 2009/ETE/R/069) the academics investigated just five bulbs. This is just the prescribed minimum.
  • Marlene Holzner, spokeswoman of the EU Commissioner for Energy, e-mailed: The EU Commission received the results of the study only in May 2010 (after the incandescent light bulb ban).

MEP Bart Staes (Groen) emphasizes: The ban on the incandescent light bulb is proclaimed by the European Commission as a part of the European climate plan: a 20 per cent reduction in CO2 by the year 2020. (...) They were conscious of the disadvantages of the classic CFL, as were the European Parliament, which could halt the decision on each moment. That they didn't do it, is because the damage did not counterbalance the benefits: an estimated energy saving by 2020 is sufficient to provide 11 million households with electricity, or a saving per family of 25 euro a year on energy cost. (De Standaard, 2 juni 2012) Other MEPs affirm that the data presented at the time by the European Commission regarding the effects of such a change [from traditional light bulbs to an energy saving technology] came from the advertising materials of the producers of these new-technology light bulbs (MEP Zbigniew Ziobro).

Debate in the British Chamber (Source)

  • The key legislation in this area [incandescent light bulbs] started with the ecodesign of energy-using products directive in 2005. That was updated and recast four years later by the ecodesign directive of 2009. Those directives set down rules on the environmental performance of products that used energy, such as light bulbs, (...).
  • The relevant Commission regulation of 2009 set out a timetable for the phasing out of the manufacture and import of incandescent bulbs. The position is that 100 W bulbs were banned in 2009, 75 W bulbs in 2010 and 60 W bulbs in 2011. The remaining 40 W and 25 W bulbs will be banned as of 1 September 2012. That regulation was not voted on by the European Parliament — it went through without debate — and it is directly applicable. That is why there is no transposing legislation at our level.

Revision of the regulation 244/2009 is scheduled for 2014.

In a letter dated 17 May 2012, the UK Government urged the Commission services to arrange for research on the relationship between artificial lighting and various health conditions before 2014, and to encourage a voluntary industry initiative which would develop a list of lamp models suitable for light-sensitive individuals along with supporting information. There has been no suggestion from the UK Government for an exemption for those with specific medical needs. (Answer given by Mr Oettinger on behalf of the Commission on a written question of MEP David Martin, E-004836/2012, 22 juni 2012)

4. Negative impact on the functionality

The results of the tests made by Test-Aankoop/Test-Achats on double envelope CFLs frightened Catherine Lootens ("Laboratorium voor Lichttechnologie" in Ghent (Belgium)). Do they realize that this year no incandescent lamps may be manufactured or imported? Concerning the introduction of the Ecodesign Directive, the researcher comments: It is very nice that Philips says that they are at the base of this evolution, but anyway, it had to be better. That was the meaning, not alone in Europe but also in the US. The management has imposed it to the manufacturers, who have done their part of the job. Not only Philips, but also the other manufacturers, such as Osram, Sylvania and Megaman. (De Standaard, June 2, 2012)

The lessened functionality of double envelope CFLs is in clear contradiction with article 15 of the Directives 2005/32/EC and 2009/125/EC and with the Commission Regulation (EC) No 244/2009.

5. Health consequences

A. Health consequences of the mercury pollution

Economic benefits of methylmercury exposure control in Europe: Monetary value of neurotoxicity prevention, published in the journal Environmental Health, 2013.

  • The hair-mercury concentrations were the highest in Southern Europe and lowest in Eastern Europe.
  • The results suggest that, within the EU, more than 1.8 million children are born every year with MeHg exposures above the limit of 0.58 µg/g.
  • About 200,000 births exceed a higher limit of 2.5 µg/g proposed by the World Health Organization (WHO).
  • Because the critical effect of MeHg exposure is developmental brain toxicity, exposures among women of reproductive age groups are of primary concern [...]. As has previously been determined in regard to lead exposure [7], developmental MeHg exposure is linked to a loss in Intelligence Quotient (IQ), with associated lower school performance and educational attainment, thereby leading to long-term impacts on societal benefits of pollution abatement.
  • The total annual benefits of exposure prevention within the EU were estimated at more than 600,000 IQ points per year, corresponding to a total economic benefit between €8,000 million and €9,000 million per year.

The content 0.58 micrograms of mercury per gram of hair is considered a safe limit. The maximum limit of 2.5 micrograms of mercury per gram of hair is considered in research circles too high. The U.S. EPA reference dose corresponds to 1.0 µg/g hair.

The greatest problem, however, is the combustion of coal, Chinese lignite in particular, which is particularly rich in mercury.

"It's incredibly important that we stop or limit the mercury emissions in the environment," says the professor [Philippe Grandjean]. "But even with a strict agreement it will take many years before we can reduce the pollution to natural levels."

"I hope that we can find agreement on a long-term strategy, which establishes some control of the pollution. In the meantime we must adapt, and pregnant women in particular should avoid eating from the top of the food chain - for the sake of the next generation’s IQ, health, career options and earnings." (Source: ScienceNordic, January 9, 2013)

B. Health consequences from the use of CFLs and LEDs

  • As a consequence of the mercury content in CFLs: A child in Germany was found with red rash. A week later, he was losing his hair. He had slept in his playroom where a CFL was broken. His parents were not aware of the dangers of mercury (this was not stated on the packaging) and had gathered the particles and glass fragments in the wastepaper bin without ventilating the room. The child was disinterested, tired and lacked energy. Fortunately, the boy recovered after a lot of treatment. (Source: Film ‘Giftiges Licht’ of Alexandra Pfeil) The Directive 2002/95/EC (RoHS) has prohibited the use of mercury in electrical and electronic equipment. Why has an exemption to this been granted for CFLs? See video in German language Schocking documentary.
  • A. SCENIHR, Light Sensitivity, September 23, 2008
  • B. SCENIHR, Health Effects of Artificial Light, March 19, 2012

More information concerning health effects can be found here

6. How did the EU justify the ban on incandescent light bulbs?

According to the DG Joint Research Centre, the generation of 1 kWh was assumed to produce 0.016 mg mercury to air. A fuel mix of 31% coal, 21% gas and oil, and 48% non fossil fuels (of which 32% of nuclear) was the base for the calculation. (See The VITO report (Final Report. Lot 19: Domestic lighting. Study for European Commission DGTREN unit D3, (2009/ETE/R/069) VITO, October 2009, p. 147)

Let us calculate the mercury emission per kWh in 2008.

Countries EU 27 Total electricity generation in 2008 Electricity produced by coal and peat in 2008 Percentage electricity produced by coal and peat in 2008 Number of facilities Hg emission to the air in 2008 Hg emission to the water in 2008 Hg emission per kWh in 2008 (mg/kWh)
Austria 67101 6898 10.3% - - - 0.0023
Belgium 84930 7235 8.5% 1 11.6 - 0.0001
Bulgaria 45037 23220 51.6% - - - 0.0115
Cyprus 5078 0 0.0% - - - 0.0
Czech Republic 83517 49823 59.7% 31 2460 12.3 0.0296
Denmark 36391 17457 48.0% 8 178 1.9 0.0049
Estonia 10581 9645 91.2% 2 501 - 0.0473
Finland 76930 14310 18.6% 4 56 - 0.0007
France 574868 27231 4.7% 9 176 7.85 0.0003
Germany 637232 290645 45.6% 55 5320 10.6 0.0084
Greece 63749 33356 52.3% 6 1550 1.1 0.0243
Hungary 40025 7205 18.0% - - - 0.004
Ireland 29685 8018 27.0% 1 35.8 - 0.0012
Italy 319130 48591 15.2% 8 169 5.39 0.0005
Latvia 5274 2 0.0% - - - 0.0
Lithuania 13912 1 0.0% - - - 0.0
Luxemburg 3557 0 0.0% - - - 0.0
Malta 2312 0 0.0% - - - 0.0
Netherlands 107645 26797 24.9% 5 144 - 0.0013
Poland 156177 143369 91.8% 22 4880 - 0.0312
Portugal 45969 11196 24.4% 7 608 1.7 0.0133
Romania 64956 25882 39.8% 6 1110 - 0.0171
Slovakia 28962 5149 17.8% 3 103 1.19 0.0036
Slovenia 16399 5323 32.5% 1 19.8 - 0.0012
Spain 313746 49973 15.9% 22 1330 4.38 0.0043
Sweden 150036 2235 1.5% - - - 0.0003
United Kingdom 389366 126699 32.5% 29 1360 62.1 0.0037
EU-27 3,372,565 940,260 27.9% 220 20,012.2 108.51 0.00623

Sources:

Result

  • The total mercury emission is 20,012.2 + 108.51 = 20,120.71 kg. However, a new consultation of the website one year later showed a total of 20,109 kg.
  • One can ascertain that some numbers concerning mercury emission are lacking in Austria, Bulgaria, Hungary and Sweden. So, a supplementary Hg emission of 0.885 tons has been added, proportional to the emission in the other countries using coal fired power plants.
  • The net production of electricity in EU-27 is 3,203 TWh (Eurostat)
  • Hg emission per kWh: 20,109 + 885 = 20,994. One obtains a Hg emission of 0.0065 mg/kWh.

The mercury emission per kWh for the years 2007-2010 is:
Year Hg emission from power plants Correction (estimate) Total Hg emission from power plants Net electricity production Mercury emitted from power plants for the production of 1 kWh (mg)
2007 22,663 kg 997 kg 23,660 kg 3,196 TWh 0.0074 mg/kWh
2008 20,109 kg 885 kg 20,994 kg 3,203 TWh 0.0065 mg/kWh
2009 16,446 kg 724 kg 17,170 kg 3,045 TWh 0.0056 mg/kWh
2010 16,243 kg 715 kg 16,958 kg 3,181 TWh 0.0053 mg/kWh
2011 16,449 kg 724 kg 17,173 kg 3,180* TWh 0.0054 mg/kWh

(*) This number is a good estimate but has still to be validated.

The discrepancy with the VITO-figure (0.016 mg/kWh) is extraordinary and very suspicious. We can only conclude that a wrong number has been sneaked in. Why was it needed? Obviously because otherwise, the CFLs could not be proven to be a better choice than the incandescent bulbs!

Calculation in the VITO-report, p. 172

Mercury emitted to air for the production of 1 kWh (mg) 0.016 mg
Percentage of collected CLFs 20%
. Clear incandescent lamp Frosted incandescent lamp Compact Fluorescent Lamp
Wattage 54W 54W 13W
Total wattage (ballast inclusive) 54W 54W 13.65W
Lifetime (hours) 1000 h 1000 h 6000 h
Total kWh during lifetime 54 kWh 54 kWh 81.9 kWh
Lumen per lamp 594 lm 572.4 lm 559 lm
Effective luminous efficiency (lumen per watt) 11 lm 10.6 lm 43 lm
Mercury emitted during the use phase (mg) 0.86 mg 0.86 mg 1.31 mg
Mercury content in lamp 0 0 4 mg
Mercury emitted by burned out lamps (mg) 0 0 3.2 mg
Total mercury emission per lamp 0.86 mg 0.86 mg 4.51 mg
Mercury emitted over lifetime per lumen per hour (nanogram) 1.45 nanogram 1.51 ng 1.34 ng
Difference with the frosted incandescent bulb - 3.6% 0.0% - 10.9%

In comparison with the frosted incandescent bulb, the CFL is only 10.9% better regarding the environmental impact, and this with a figure of mercury emission from power plants which is almost three times too high!

What would be the mercury pollution (same lamps) using the real mercury emission calculated with the data of 2008?

Mercury emitted to air for the production of 1 kWh (mg) 0.0065 mg
Percentage of collected CLFs 20%
. Clear incandescent lamp Frosted incandescent lamp Compact Fluorescent Lamp
Wattage 54W 54W 13W
Total wattage (ballast inclusive) 54W 54W 13.65W
Lifetime (hours) 1000 h 1000 h 6000 h
Total kWh during lifetime 54 kWh 54 kWh 81.9 kWh
Lumen per lamp 594 lm 572.4 lm 559 lm
Effective luminous efficiency (lumen per watt) 11 lm 10.6 lm 43 lm
Mercury emitted during the use phase (mg) 0.35 mg 0.35 mg 0.53 mg
Mercury content in lamp 0 0 4 mg
Mercury emitted by burned out lamps (mg) 0 0 3.2 mg
Total mercury emission per lamp 0.35 mg 0.35 mg 3.73 mg
Mercury emitted over lifetime per lumen per hour (nanogram) 0.59 nanogram 0.61 ng 1.11 ng
Difference with the frosted incandescent bulb - 3.6% 0.0% 81.5%

You can test it yourself, page 1: 'VITO report'!

So, with the real numbers concerning mercury emission, the damage inflicted to the environment is almost twice if one uses CFLs instead of incandescent bulbs! With false arguments the European Commission convinced the European Parliament and the people to choose the polluting mercury containing bulbs instead of the clean bulbs. The condition, that the power plants attain a sufficient high level of mercury emission to 'justify' the mercury containing CFLs, was articially implemented in the numbers. A dirty game has been played by the European Commission.

One could already deduce that something was wrong with this number. In the US, where the fuel mix in 2008 was 48.8% coal, 22.1% gas and oil, and 29% non fossil fuels (of which 19.2% of nuclear) EPA assumed a mercury emission of 0.012 mg/kWh. Also this number is found by me too high. See page on incandescent ban in the US.

  • But more is at stake. The European Commission has justified CFLs because of this high level of mercury emission by power plants. But what if the emission is much lower? In that case, if the EC is consequent with its principles, all CFLs have to be withdrawn from the market.
  • In the reasoning of the European Commission, lamp manufacturers are allowed to produce and sell CFLs because the mercury pollution is extremely high. To them is allowed to make profit while the air pollution is very toxic. Only a criminal organization can make such plans. The only healthy solution is to implement a zero emission of mercury.
  • Another critique is that the EC keeps the old number of mercury emission on their website, even when this number do not apply with reality. They know very well that in the years when the VITO-report was published, the number conerning the mercury emission per kWh was too high. Now that this emission has decreased still more, they keep this old number as the base of their calculations. Lamp manufacturers are allowed to sell CFLs even when incandescent light bulbs emit less mercury. That more mercury emission is promoted due to the use of CFLs, is a second criminal fact.

Conclusion:

  • The overall mercury balance of CFLs is NOT positive. During its lifetime it will NOT have saved more mercury emissions from electricity production in coal power plants (compared to the mercury emissions related to the conventional incandescent bulbs' electricity need) than is contained in the CFL itself.
  • The number concerning the mercury emission from power plants ('0.016 mg/kWh') has never been proven. VITO has accepted the figure unquestioningly.
  • Meanwhile, based on this wrong calculation, wrong information concerning the CFLs has been dished up to the European Parliament and to the people.
  • It is obvious that CFLs should never have been authorized by the European Commission because of the mercury content. Only wrong data of the mercury emission by power plants could let it happen.
  • The European Commission didn't shrink from designating CFLs as environmentally friendly. In other words: we had to use more mercury in order to diminish the mercury emission by power plants! The only valid way to reduce the mercury in the environment is to limit the toxic emission from power plants and not to impose the use of CFLs on the consumers. Take the pollution away and the CFLs become obsolete!
  • Compare the mercury emission of a clear incandescent bulb, a halogen lamp (42 W, lifetime of 2000 hours, 630 lumen) and a CFL (lifetime of 6000 hours). With a mercury emission of 0.012 mg/kWh from the power plants, the halogen lamp will be the best choice. (Test it!).
  • How is the mercury emission from power plants divided among the countries of EU-27?
    • The countries in Europe with a higher emission rate of mercury than 0.012 mg/kWh are: Estonia, Poland, Czech Republic, Greece, Romania and Portugal 2008. These six countries were in 2008 responsible for 55% of the mercury emission from power plants!
    • The countries with an emission of mercury between 0.003 and 0.012 mg/kWh are: Bulgaria (?), Denmark, Hungary, (Portugal 2009), Slovakia 2008, Spain 2008, Germany and the United Kingdom. The introduction of CFLs in these countries has led to an increase of the mercury pollution.
    • The other countries are producing electricity with a limited or no danger of mercury pollution: Austria, Belgium, Cyprus, Finland, France, Ireland, Italy, Latvia, Lithuania, Luxemburg, Malta, Netherlands, Slovenia, Sweden (Slovakia 2009 and Spain 2009). The introduction of mercury containing CFLs in countries where electricity is generated on a clean manner is a crime against humanity and against the environment.
  • Due to the seriousness of this question, an inquiry has to be started which has to elucidate the real impact of the mercury pollution by CFLs in the environment in Europe. Those who have made possible this introduction have to appear before the judge!

7. The question of the CO2 emission

The generation of electricity in EU leads to the emission of about 1,400 million tons CO2 (0.42 kg/kWh). If no CO2 or mercury was emitted by power plants, no measures (i.e. a ban of incandescent lamps) were needed in the household sector.

The European Union has set itself the target of cutting its overall consumption by 20% by the year 2020. One of the means of achieving this was to be the replacement of conventional light bulbs by energy-saving bulbs. The conclusion of a study by American scientists publicised in the British magazine The Economist is, however, that in the longer term energy-saving bulbs will not cut energy consumption, but may on the contrary increase it. (Question of MEP Jan Březina, E-8356/2010)

The answer given by Mr Oettinger on behalf of the Commission was: The impact assessment of Commission Regulation (EC) No 244/2009 phasing out incandescent bulbs already assumed that a 15 % increase would take place in the number of lamps installed in the domestic sector between 2007 and 2020, as a result of economic growth. Still, the electricity consumption of the domestic lighting stock should decrease from 112 terawatt-hours in 2007 to 96 terawatt-hours in 2020 (instead of rising to 135 terawatt-hours without the measure in place). This means an estimated saving potential of 39 TWh, 1.4% of the electricity consumption of the year 2006 (2826 TWh) or 5% of the of the electricity consumption of the household sector in the EU. It is roughly the electrictity consumption of Romania, or of 11 million European households. Here is assumed that the households will be using a mixture of improved incandescent bulbs with halogen technology and compact fluorescent lamps. (These figures can also be found in the VITO report, p. 303-304 and p. 312-313.)

The saving can be still higher if is assumed that the households switch to the exclusive use of compact fluorescent lamps and LEDs. If all households switched to the exclusive use of compact fluorescent lamps and LEDs, total savings at the EU level would be about 86 billion kilowatt-hours by 2020, which is 11 % of the electricity consumption of households. (Answer given by Mr Oettinger on behalf of the Commission on the question of MEP Konrad Szymanski (E-0862/2010))

The facts are that in Germany in the region Nordrhein-Westfalen alone, twelve coal-fired power plants are being built. Since 2009, the share of coal is growing in Germany's electricity generation: 257 TWh in 2009 and 274 TWh in 2010. In Europe, a severe legislation was ordered to ban the incandescent bulbs in order to decrease the emission of CO2, but in Germany, an increase of CO2-emission by power plants was seen last years. In 2011, the specific CO2 emissions from electricity generation plants for public power supply was 0.51 kg CO2/kWh net. "With respect to the previous year (0.49 kg CO2/kWh net), they have risen about 4%!" (Source)

N.B.: Heating represents 70% of household energy consumption and about 14% of EU greenhouse gas emissions. Reducing home temperature by 1°C would cut down CO2 emissions by 300 kg a year for each household. (Source) An extreme and blind operation as banning the incandescents was not necessary.

8. The share of lighting in the energy consumption

  • In 2007 final electricity consumption in EU-27 represented around 21% of final energy consumption. The final electricity consumption was about 2800 TWh.
  • This 800.72 TWh (electricity consumption of the household sector) is subdivided in:
  • In 2007, residential lighting represented 10.5% of the residential electricity consumption and 3% of the total electricity consumption. In some EU publications, the "total residential electricity consumption" is calculated with the exclusion of water and space heating from residential electricity consumption! Example 'Powering the Nation'. In our case, this should have the result that the residential lighting represented 14.4% of the residential electricity consumption! On this manner one is exagerating the importance of the share of lighting. The equivalent electricity consumption of the incandescent lamps represents more than half, 56%, halogen lamps being responsible for around 31%. (Electricity Consumption and Effiency Trends in European Union, p. 38.) The number "84" is based on the data of DG Joint Research Centre. The VITO report (Final Report. Lot 19: Domestic lighting. Study for European Commission DGTREN unit D3, (2009/ETE/R/069) VITO, October 2009, p. 303) has the number 112 TWh, and this concerns only non directional domestic lighting for the year 2007.
  • In 2009, lighting electricity consumption in the residential sector is estimated to represent 10% of the total residential electricity consumption. (Source: Paolo Betoldi, e.a., Electricity Consumption and Efficiency Trends in the EU-27, 2012, p. 124)

The consumer is responsible for his choices concerning lighting products. Important criteria are the quality of light, the absence of harmful substances and of UV radiation, a short warm-up time, etc. Lamps which do not meet these criteria cannot be imposed.

8. The answer of the European Commission to my letter

  • On 31 August 2012, I wrote the following letter to the EU Commissioner Günther Oettinger.
  • On 18 October 2012, the following answer was sent to me from "EUROPEAN COMMISSION, DIRECTORATE-GENERAL FOR ENERGY, Directorate C - Renewables, Research and Innovation, Energy Effenciency; Energy efficiency; Head of Unit.
My letter of 31 August 2012 Answer dated 18 October 2012 My comment
No subject mentioned Subject: Request for information concerning norm requirements for water pumps An obvious mistake (made by stressed public servants?)
Article "Test Spaarlampen" (Test low-energy light bulbs) in the periodical "Test-Aankoop/Test-Achats” (Belgium) of June 2012: it is said that the recycling of used bulbs is not always as good as it should be. They usually end up in an ordinary plastic bin. In some places [of the collection point for polluting waste] lay broken lamps. That mercury is released in this way, one hardly does realize it. (Belgian newspaper De Morgen, CFLs are not always environmentally friendly, 25 May 2012) Moreover, the Waste Electrical and Electronic Equipment Directive (Directive 2002/96/EC*) provides for the collection and recycling of waste electrical and electronic equipments, including compact fluorescent lamps. Since 2005, mercury containing lamps have to be collected separately and the mercury has to be removed. More detailed information on how to dispose of energy-saving bulbs can be found on the above mentioned website of the Energy DG: http://ec.europa.eu/energy/ Do they really think that with a link to a website, all consumers will dispose of their CFLs on the right manner? The result of a recent inquiry was that only 45% of the 60,000 interviewees in the Netherlands said to put their CFLs in a collection point for polluting waste. (Source: Dutch film 'De donkere kant van de spaarlamp' (The Dark Side of the CFL))
An investigation by the Environment Administration in Belgium is also going on. Some ‘fast start’ CFLs contain more mercury than the allowed 3.5 mg. The results of this investigation will be published in October 2012. (Source: the newspaper Le Soir, 30 August 2012) The amount of mercury in Compact fluorescent lamps (CFLs - usually referred to as "energy saving lamps") is very low - a maximum of 3.5 mg of mercury per CFL since January 2012 (Directive on Restriction of Hazardous Substances "RoHS") compared to 50 mg in cell batteries, 500 mg in amalgam fillings and several grams in old thermometers. The limit will be lowered to 2.5 mg from January 2013. The control of the mercury content of CFLs leaves a lot to be desired. Also has to be emphasized that the liquid form of mercury is the least dangerous. Mercury vapor is very dangerous because it is absorbed quite easy by the lungs. In a room, a maximum of 300 nanogram of mercury is allowed over a long time. When a CFL is broken, one can measure 10,000 nanogram or 33 times too much! (Source: Dutch film 'De donkere kant van de spaarlamp' (The Dark Side of the CFL))
Not only do the harmful effects of fluorescent lighting need to be considered but also the environmental damage done during the production phase (mainly in China where workers suffer mercury poisoning at the expense of the western world), the recycling problems and the rights of the consumer. The overall mercury balance of CFLs is positive. Even in the worst possible case that a CFL goes to the landfill, during its lifetime it will have saved more mercury emissions from electricity production in coal power plants (compared to the mercury emissions related to the conventional incandescent bulbs' electricity need) than is contained in the CFL itself, so the overall mercury pollution balance will be positive. Airborne mercury emission from power plants is deposited in the Arctic sea, where it turns into highly toxic methylmercury and is absorbed by fish. Through the fish, the entire EU population is exposed to mercury poisoning, not just the countries where coal-fired power plants are operating. See point 5 on this page and the conclusions. The whole explanation boomerangs in the face of the European Commission. If one wants to limit the mercury emission, one has to cut the presence of mercury, not only in all the products on the market but also in the fuel mix used in power plants.
One should not forget the victims of broken CFLs. A child in Germany was found with red rash. A week later, he was losing his hair. He had slept in his playroom where a CFL was broken. His parents were not aware of the dangers of mercury (this was not stated on the packaging) and had gathered the particles and glass fragments in the wastepaper bin without ventilating the room. The child was disinterested, tired and lacked energy. Fortunately, the boy recovered after a lot of treatment but this could well not have been the case. (Source: Film ‘Giftiges Licht’ of Alexandra Pfeil) The Directive 2002/95/EC (RoHS) has prohibited the use of mercury in electrical and electronic equipment. Why has an exemption to this been granted for CFLs? The risks for children have been newly assessed by SCHER. Regarding specifically the oral intake and according to preliminary information available in the meantime from the German Federal Agency for Environment (UBA) and the Dutch National Institute for Public Health and the Environment (RIVM), the risk for children by an (oral) intake of mercury via household dust is low. 'Contra facta nihil valent argumenta' (No valid arguments exist against facts.) More information concerning the answer of the Commission can be found on this page.
Many consumers want to use only incandescent bulbs for their desk lamps and reading lamps. This is a very reasonable request. Consumers must have the right to buy the most appropriate products to meet their well-considered needs. The ban on incandescent lamps means a violation of the free market principles. From the beginning it was a very strange that the European Commission decided to end the production of mercury thermometers while on the other hand, consumers were compelled to use compact fluorescent light bulbs, which contain mercury. Finally, please note that contrary to the impression prevailing in public debates, consumers do have a choice and are not forced to buy CFLs. Regulation on non-directional household lamps (Regulation 244/2009) only sets minimum efficiency requirements for "non-directional" lamps typically used in households. Consumers therefore can choose alternative lamps, like improved incandescent (halogen) lamps (same characteristics as the traditional light bulb, but only 25% energy savings). In addition, LED-lamps - the technology of the future - have started to enter the market. For most people, the only alternative lamps for the incandescent bulbs are CFLs and improved incandescent lamps. Both can emit significant levels of UVA, UVB and UVC. LED lamps are still to expensive.

NO ANSWER was given by the European Commission to the following remarks:

  1. Incandescent bulbs were substituted by inferior products.

    • Concerning single envelope CFLs: Professor Rafailovich writes: "Our paper simply points out that defects in the coating are in fact ubiquitous, and the potential for exposures to harmful levels is always present." (See the study of the Stony Brook University on this page.)
    • Concerning double envelope CFLs: As already mentioned, the consumers' organization "Test-Aankoop/Test-Achats" (Belgium) tested 13 double envelope compact fluorescent lamps, including one ‘fast start’ CFL. They found the following astonishing results:
      • No lamp reached half the full intensity of light within 30 seconds. The spokesman Ivo Mechels commented: These teething troubles can no longer be justified.
      • The lifetime of the lamps does not always correspond to the promised lifetime on the packaging. Six of the thirteen species scored very poorly, said Mechels.
      • The brightness is 30% at the end of life in some lamps
      • Some lamps failed very early in the ‘switching on and off’ test.

      The author of the article concludes: Double envelope energy saving lamps are the most obvious alternative to the vanishing incandescent bulb. Hopefully the manufacturers will truly succeed to ensure that these lamps will become a worthy replacement for them. Similar results can be found in the German consumers' magazine Öko-test (Öko-test, Jahrbuch: Bauen, Wohnen und Renovieren für 2010, 09/09), in Stiftung Warentest in the periodical 'Test' (April 2010) and in a test by the Finnish newspaper Aamulehti.

      We urgently need to know why the warm-up times are too slow in all the double envelope CFLs tested in the Belgian search. The manufacturers still do not comply with the ecodesign requirements for non-directional household lamps. This is unacceptable, four years after the introduction of the regulation. The consumer has been left out in the cold by the European Commission. Consumers have been saddled with a dangerous and unreliable product. Something peculiar is going on here.

    • No new investments are being realized in the CFL technology: This trend to invest in LED lighting is happening in all major lighting manufacturers. Research on the CFL technology is no longer a priority for them. They seem to have given up on CFL technology because the sale of LED lamps is much more lucrative. Their new research will exclusively be on LED technology. Meanwhile, the CFLs on the market do not meet the standards required by the Regulation and this will not change in the future.

    Conclusion:

    • Both single and double envelope CFLs are showing faults and do not meet the required standards.
    • The lighting manufacturers are not longer interested in the CFL technology.
    • Consequence of both previous statements: The consumers are saddled and will remain saddled with inferior products.
  2. SCENIHR has presented a list of potential research needs related to the areas where the lack or scarcity of scientific evidence prevents SCENIHR from coming to firm conclusions. Despite the list, the European Commission is drawing firm conclusion.
  3. The rights of the consumer are seriously damaged. The Commission does not factor in the quality of light, the frustrating time lag before the lamps emit full light, the cosy and warm atmosphere produced by incandescent lamps. The quality of light is imperative for the consumer. Since its invention, consumers have benefited from the pleasant and agreeable spectrum of incandescent lamps. Many consumers want to use only incandescent bulbs for their desk lamps and reading lamps. This is a very reasonable request. Consumers must the right to buy the most appropriate products to meet their well-considered needs. The ban on incandescent lamps means a violation of the free market principles.
  4. The question was asked: "How can you justify in this context that more and more coal plants are being opened in the European Union?" More coal-fired power plants are being built in the EU and more specifically in Germany. This totally invalidates the argument of the EU that the ban of incandescent bulbs will decrease the CO2 emission. (See point 6 on this page.)

Conclusions for the future:

  1. Consumers cannot wait until 2014 for their justified demands to be met. For the sake of the many victims of the ban on incandescent lighting, the European Commission must acknowledge that this measure was ill-considered, premature and without public discussion. We all know how consumers’ demands were denied under dictatorial regimes but this is now happening to us as citizens of the European Union!
  2. It is also essential that this mistake is not repeated with directional lighting.
  3. A simple and accessible scheme has to be introduced to compensate those citizens who have suffered damage and ill-health from the EU’s decision to ban incandescent light bulbs. It is unacceptable that consumers have to pay such a high price, both personally and financially, in order to meet the fixed CO2 emission standard. Other more appropriate measures are possible.

The discussion about health effects are treated on this page.

10. Some relevant passages from the European legislation

Official information from the EU: The replacement plan encloses to gradually replace incandescent light bulbs with energy-saving or halogen ones by 2012. The replacement plan was proposed by the European Commission in December 2008, and then approved by Member State experts in the Eco-design Regulatory Committee. Parliament has until 15 March to oppose it, if it so wishes.

In today's vote [17 February 2009], MEPs rejected a resolution opposing the plan with 14 votes in favour, but 44 against. So in effect, the EP Environment Committee has approved the plan, under which incandescent bulbs are to be gradually phased out from September 2009 to 2012. The rejected resolution, drawn up by Holger Krahmer (ALDE, DE) and Anja Weisgerber (EPP-ED, DE), said that a product such as light bulbs should not be banned via a regulatory committee procedure.

See also the answer of the EU on the question of MEP Franz Obermayr:

  • The decision to phase out conventional inefficient light bulbs was taken by the Heads of State and Government at the European Summit under the German presidency in 2007.
  • The European Parliament stressed the importance of the Commission keeping to the proposed timetable for the withdrawal of the most inefficient light bulbs from the market (In its resolution of 31.1.2008 on the Action Plan for Energy Efficiency).
  • The implementing Commission regulation on non-directional lamps in households had been developed in a comprehensive process involving consultation of all relevant stakeholders and with formal positive opinion adopted by the regulatory Committee, with the European Parliament and the Council exercising full scrutiny.

The Commission Regulation (EC) No 244/2009 is part of the Ecodesign Framework (Directive 2009/125/EC of the Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products, OJ L 285, 31.10.2009) under which 14 measures have been put in place. They are estimated to save by 2020 around 400 TWh annually (Representing about 12% of the EU annual electricity consumption).

European legislation

  • Concerning mercury pollution by CFLs: Commission Regulation (EC) No 244/2009 of 18 March 2009 (ecodesign requirements for non-directional household lamps):
    • (9) Mercury emitted in the different life cycle phases of the lamps, including from use-phase electricity generation and from the 80 % of compact fluorescent lamps containing mercury which are presumed not to be recycled at the end of life, has been estimated to be 2,9 tonnes in 2007 from the installed stock of lamps. Without taking specific measures, the mercury emissions of the installed lamp stock is predicted to increase to 3,1 tonnes in 2020 while it has been demonstrated that it can be significantly reduced.
    • (14) The ecodesign requirements should not affect functionality from the user’s perspective and should not negatively affect health, safety or the environment. In particular, the benefits of reducing the electricity consumption during the use phase should overcompensate potential, if any, additional environmental impacts during the production phase of products subject to this Regulation.
    • Article 7: Revision The Commission shall review this Regulation in light of technological progress no later than five years after the entry into force and present the result of this review to the Consultation Forum.
  • Concerning the ecodesign requirement on ultraviolet radiation: Commission Regulation (EC) No 859/2009 of 18 September 2009 amending Regulation (EC) No 244/2009 as regards the ecodesign requirements on ultraviolet radiation of non-directional household lamps
    • (1) According to evidence produced after the adoption of Regulation (EC) No 244/2009, the limit set in Table 5 of the Regulation regarding ultraviolet radiation of the UVC type cannot be met by tungsten halogen lamps without a second lamp envelope (notably mains voltage halogen lamps with G9 and R7s caps but also extra low voltage halogen lamps). This would result in banning those lamps from the internal market from 1 September 2009.
    • (2) The phasing out of G9 and R7s cap lamps is considered only in a longer term, as they are widely used and there is presently no suitable replacement available that would fit into the luminaires designed for such lamps.

    NB: More about the mentioned lamp holders (G9 and R7S) can be found here.

  • Concerning the directional household lamps and LEDs: 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 of directional lamps, light emitting diode lamps and related equipment.
  • Concerning the ecodesign requirements for energy-related products:
    • 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
      • (2) Energy-using products (EuPs) account for a large proportion of the consumption of natural resources and energy in the Community.
      • (4) Energy efficiency improvement - with one of the available options being more efficient end use of electricity - is regarded as contributing substantially to the achievement of greenhouse gas emission targets in the Community.
      • (21) EuPs complying with the ecodesign requirements laid down in implementing measures to this Directive should bear the 'CE' marking and associated information, in order to enable them to be placed on the internal market and move freely.
      • (Article 15) Implementing measures shall meet all the following criteria:
        1. there shall be no significant negative impact on the functionality of the product, from the perspective of the user;
        2. health, safety and the environment shall not be adversely affected;
        3. there shall be no significant negative impact on consumers in particular as regards the affordability and the life-cycle cost of the product;
        4. there shall be no significant negative impact on industry's competitiveness;
        5. in principle, the setting of an ecodesign requirement shall not have the consequence of imposing proprietary technology on manufacturers;
        6. no excessive administrative burden shall be imposed on manufacturers.
    • 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
      • (6) Energy efficiency improvement — with one of the available options being more efficient end use of electricity — is regarded as contributing substantially to the achievement of greenhouse gas emission targets in the Community.
      • (13) The approach set out in the Commission’s Communication of 18 June 2003 entitled ‘Integrated Product Policy — Building on Environmental Life-Cycle Thinking’, which is a major innovative element of the Sixth Community Environment Action Programme, aims to reduce the environmental impacts of products across the whole of their life cycle, including in the selection and use of raw materials, in manufacturing, packaging, transport and distribution, installation and maintenance, use and end-of-life.
      • (23) Energy-related products that comply with the ecodesign requirements laid down in implementing measures to this Directive should bear the "CE" marking and associated information, in order to enable them to be placed on the internal market and move freely.
      • (Article 15) See Directive 2005/32/EC

Conclusion: CFLs should be banned while the ban on incandescents lamps should be lifted immediately!

References:

Last update on 25 April 2015