Update 13: May 2021
by Rob Halliday
It doesn’t feel like any time at all since I last wrote an update about this - but in fact it’s been nearly a year. It’s funny the different rate time seems to have passed during the various lockdowns.
Last year, I wrote that we’d worked with the EU to tidy up the final details of their Ecodesign regulation, correcting the little anomalies that had crept in and could have threatened the availability of, in particular, high-output white LED-based lighting fixtures, things like followspots or stadium-scale moving lights. Those corrections were voted on and accepted as part of the ‘Omnibus amendments’ to the Ecodesign regulations in November 2020. Job done...
Except of course that those regulations don’t come into effect until later this year, September 2021. Which means these rules weren’t in effect last Christmas at the point of that little thing called Brexit - so they didn’t automatically become part of UK law as part of that process. Job not quite done.
A few days after the Omnibus amendments were accepted last November, an email arrived from the UK Government’s Department of Business, Energy and Industrial Strategy (BEIS), which oversees this regulation in the UK. They were starting a consultation on the new draft Ecodesign and Energy Labelling Regulations (Light Sources) 2021 for the UK...
In effect, as a starting point, they had copied and pasted the EU regulation and changed the title. Unfortunately in an unfortunate fluke of timing, they’d copied and pasted the pre-Omnibus, so without any of the corrections we’d worked so hard to achieve. Deep sigh...
BEIS were running a public consultation on this, and while we completed that alongside PLASA and the other members of the Ecodesign coalition, we also got in touch with BEIS directly. Interestingly this was now largely a different team of people to those we’ve dealt with there over the last few years, and so it was almost like starting all over again in terms of explaining what we do and our issues, but the new team seemed receptive and interested. The result is that their text has been updated to the Omnibus edition, and so UK law (in England, Scotland and Wales at least) and EU law will continue to match - for now.
How long that continues to be the case is anyone’s guess. In early discussions it felt like the UK team thought the EU regulations were overcomplicated, full of strange exceptions and workarounds. The hint was that BEIS would like to throw that all away and get back to a very simple lumens-per-watt efficiency requirement. Of course that’s what the EU also wanted to do; we fought that for very good reason, and other industries that use light fought their cases for their own very good reasons, which is why the regulation ended up so complicated. I suspect the issue is really that it is trying to deal with too many disparate uses of light, from domestic lighting to tanning to industrial processes. Through the responses to their public consultation and a couple of on-line panels they held which we took part in, I think BEIS have understood that and are now re-considering their approach.
Meanwhile in Europe, the EU is starting to plan their next set of revisions to Ecodesign. It feels like there is a realisation that further big reductions to energy use will be hard to achieve, and so attention is turning to improving the working life of products, their repairability and, ultimately, their recyclability. Some of these aspirations were in drafts of the current Ecodesign regulations but were ultimately edited out. Bringing them back would be no bad thing.
The danger, of course, is if the EU does one thing and the UK something entirely different (in Ecodesign, and in other regulations such as ROHS which the EU is currently updating and which we are also monitoring), which would be a challenge particularly for manufacturers selling in to both markets. That’s really what we’re keeping an eye on now, all of the organisations who’ve collaborated in this process up to now, co-ordinated through Pearle in Brussels, having agreed that we’ll keep working together and will keep presenting our case and promoting our interests jointly to the EU and to the UK so the message remains consistent.
As I said last year, what all this means for end users is that manufacturers will be allowed to keep on selling pretty much all of the products you know and love, fixtures and bulbs - with the key exception of tungsten M16 lamps which were always really a key target for Ecodesign. But as I also said last year, whether they actually want to keep on selling or even making those products is a whole other question, and there are a whole raft of tungsten bulbs that are now out of production. If you relied on those products for your rig, how you dealt with that was always going to be a challenge, all the more so after a year of no income. But ignoring the problem and doing nothing won’t change anything, and as before the ALD continues to be here if you need advice on how you could evolve your lighting system without sacrificing the quality of light that is so important to us all.
The EU Moving Forward
The UK Moving Forward
Update 12: 4th August 2020
by Rob Halliday
Remember when protecting the light bulbs we love from the EU regulators felt like the most pressing thing in the world....?
How times change!
However, even as Coronavirus has taken over everyone’s attention, work has been continuing behind the scenes on the EU’s new Ecodesign regulation to ensure that it does not impact stage lighting, so that we’re free to continue to use the lighting tools we love whenever we get to do lighting again!
To provide a quick summary of what happened and where we currently stand:
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In late 2017, the ALD became aware that new ‘Ecodesign’ regulations proposed by the EU to start from September 2020 would dramatically impact the tools we use for show lighting. In particular, by tightening up the efficiency requirements light sources would have to meet before being allowed to be sold, and removing an existing exemption for stage lighting applications, many of the light sources we love - tungsten, arc and LED - would potentially become unavailable.
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At the start of 2018 the ALD launched the ‘Save Stage Lighting’ campaign to bring attention to the issue. The campaign, which included projecting Save Stage Lighting on key arts venues across Europe, attracted widespread attention across the live entertainment community, through the national press and media (with ALD members appearing on television and radio), with MP and MEPs submitting objections and an on-line petition attracting over 84,000 signatures.
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The ALD submitted a response to the EU outlining the issues, and produced a document for its members explaining the issues.
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The ALD led several meetings with the UK Government’s Department of Business, Energy and Industrial Strategy (BEIS), the department responsible for these regulations in the UK.
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The ALD achieved support from leading theatre producers and the Society of London Theatre, and worked with other trade associations and manufacturers from across Europe to raise these issues with the EU via Pearle, the European theatre producers' organisation in Brussels. As a result a group from entertainment lighting was invited to meet with the EU team in May 2018, and was asked by the EU to produce a technically based exemption for stage lighting.
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This work was duly carried out, and was largely accepted by the EU and incorporated into the final draft of the new regulation.
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This meant that most of the light sources we use for show lighting (including most tungsten light sources, with the exception of MR16-style lamps, arc sources and white and colour-mixing LED fixtures) were exempt from the regulations and so could continue to be sold. At the same time the start date of the new regulation was pushed back from September 2020 to September 2021.
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At a post-meeting Ecodesign party, the EU team specifically mentioned and welcomed the entertainment lighting community to the Ecodesign community!
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The final text of the new regulation was published in December 2018. The entertainment community quickly identified that while it largely resolved all of the issues surrounding entertainment lighting a subtle change in wording of one section (annex III point 3(w)), the reasons for which were not really understood, meant that an exemption would not be available for some special-case light sources, including high CRI LED sources, high light output LED sources (as you might use in a long-throw moving light or followspot), and the fluorescent sources still used in the film world
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This issue was raised with the EU in early 2019. In a direct phone call between the ALD and the EU official in charge of this regulation, the EU agreed that this change did go against the goals of Ecodesign (since it would allow arc sources to continue to be used but would in some cases prevent them from being replaced by more efficient LED sources), and would potentially present a conflict with the goals of the ROHS regulations then being reviewed (since if LED replacements for arc lamps were not allowed, there would be a need to provide an exemption for arc lamps from the ROHS regulations, despite an ambition to stop their use because they contain mercury), and so should be addressed.
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Work has continued on this since. Entertainment lighting was part of a Zoom meeting with the EU in July 2020 during which this was discussed and entertainment lighting proposed a number of possible solutions.
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Entertainment lighting has since been given indications that the EU will amend this section in a way that will likely allow the sale of high-powered white LEDs and fluorescent sources.
In other words, by identifying the issue, drawing attention to the issue, engaging with the political process about the issue, providing solutions to the issue and continuing to be involved with ongoing discussions about the issue (and related issues - the ALD is also keeping an eye on the EU’s review of its ROHS regulations), the issue was resolved to the general satisfaction of all who are involved in entertainment lighting.
- The result is that the tools we need and use and love can generally continue to be supplied - though of course in many cases the issue is becoming that though they can legally be supplied, manufacturers might not continue making then, as is already the case with any number of specialist tungsten bulbs and with M16 style tungsten sources.
That’s what presents the biggest issue now, particularly to smaller venues who may not be able to afford to upgrade to newer equipment (or larger venues who may also not be able to afford such upgrades in a financially difficult post-coronavirus world). Though there is perhaps some hope in the money the government is announcing to support green measures - argue that a new LED lighting system is more efficient than an existing tungsten lighting system, and perhaps some of that money could be channelled that way?
Plus of course there’s the slight lack of clarity about what happens as the UK leaves the EU, though its likely the UK will follow this regulation at least to start with, and that manufacturers will follow the EU regulations even for products sold in the UK rather than creating ‘special’ UK versions of products. We certainly don’t expect the UK to produce stricter regulations than the EU, at least in the near-term.
The ALD continues to be here to offer support and advice to any organisation faced with these issues and trying to find the most efficient, cost effective solutions without sacrificing the quality of light which should be at the heart of everything members of the ALD do.
# Click Here for a link to the full EU Ecodesign Regulation
The previous news and updates have been archived in a document that is available from this link.
Be Part of the Conversation
To continue to bring more voices forward discussing how it will affect both the practice of lighting designers and practicalities and costs that venues will face:
The Save Stage Lighting Campaign can be found:
Facebook: https://www.facebook.com/SaveStageLighting/
Twitter: @SaveLighting
Email: savestagelighting@thealpd.org.uk
A list of those companies and individuals who are Standing With Us and supporting the campaign, while the coverage we have received from press and media outlets can be found here.
