The last update was written just a few days after the meeting with DG Energy in Brussels, when the entertainment industry had, in effect, been asked to submit ideas for a suitable exemption for stage lighting. The proposal submitted included a reference to the existing European safety standard for stage and studio luminaires (EN60598-2-17), plus a list of lamp bases used in entertainment lighting fixtures. We felt both were required since the standard would define fixtures with built-in light sources (ie. LED fixtures) but not those using separate light sources (eg. tungsten or arc lamps), while the list of lamp bases would define those light sources, tungsten and arc, we felt were important for our work; limiting the exemption to their use in already-defined stage and studio luminaires would, it seemed to us, reduce or remove the potential for an exemption for these bulbs to be abused by people outside entertainment lighting – something DG Energy have repeatedly suggested happened with the previous entertainment lighting exemption, without ever really explaining that abuse.

That proposal was submitted through PEARLE, the pan-European producers organisation which has become our “channel” into Brussels.... and then the silence began. Silence on our side because we’d all been asked to be quiet and let the EU do its work. Silence on their side, because it was doing its work. We were told that a next draft would appear in the first week of July; we waited...

Finally, on 16 July new drafts for both the Ecodesign and EcoLabelling regulations and their corresponding Annex documents (dated 3/4 July) appeared...

Silence over, time for some new reading to begin!

The Key Change

What the reading reveals is that we have made DG Energy understand that entertainment lighting is something of a special case, that there is now language in the text very specifically about entertainment lighting – but that more discussions are required just to be clear that the exemption gives us all we need.

For us, there are two points of Annex III (Exemptions) of the Ecodesign Annex document. Point 3m details

“halogen light sources with cap-type GX9.5, GY9.5, GZ9.5, GP9.5HPM, G16d, GX16, GX16d, GY16, G22, G38, GX38, GX38Q, P28s, P40s, PGJX50, QXL, designed and marketed specifically for scene-lighting use in film-studios, TV-studios, and photographic-studios, or for stage-lighting use in theatres, discos, during concerts or other entertainment events”. That covers many lamps we use and love, including the Source Four’s HPL, the Revolution’s QXL, 1k and 2k Fresnel lamps, lamps for fixtures like the Brio, SL and CCT Freedom, lamps for older fixtures such as the Patt 23/123, Par64 lamps and more.

Point 3n details “colour-tuneable light sources” that can be set to at least the colours defined as “white light” by the EU – in effect, multi-coloured additive colour mixing LED sources.

While the EU seems to have decided not to make any reference to the EN standard we proposed, they have clarified many other points. Key is that the measurement is of the light source, outside of the optical system and excluding any other functionality; if the light source is built in to a fixture it has to be removed for testing. That should make it easier to hit both the efficiency and standby power requirements, since there are no losses through the optical train to worry about and you can remove non-lighting power consumption (displays, fans, motors).

Alongside that, it has been clarified that while a simple lumen per watt calculation is used for the new A-G EcoLabelling scheme (with “G” anything 85lm/W or below), a different, more complex calculation, including corrections for different source types and colour qualities, is the one used to determine whether a product is allowed or not. Most of the common arc sources we use seem to pass this test, as do many low-powered white LED sources, though achieving the targets for high power white LED sources will be harder. However, manufacturers have an extra year to achieve this: another key change is that the proposed start date is a year later than before, September 2021. Curiously, even products that are exempt from the Ecodesign regs will have to follow the EcoLabelling regs; that probably means no one will sell a tungsten or arc fixture with a bulb included, since without a light source the fixture itself is not subject to either regulation.

Problem Solved?

Nearly, but as ever, the devil is in the details. One particular issue is that just 17 lamp bases are included in the exemption, considerably less than the 49 we submitted. Truth be told, we never expected some of these to get through – the M16 lamp is too widely used in domestic/office lighting and is clearly a target for the EU. Some are safe because they sit above the 82000 lumen upper limit. Some – beamlight, Svoboda and ACL lamps – are potentially safe because they originally come from the marine or aero fields which have their own exemptions, though it’d be nice to be sure. The R7 linear lamp used for cyc lighting and much else is still unclear because we think there’s a typo in the current draft; we’ve asked for clarification. The rest? At the time of writing, we’re still checking.

Please do look at the list, compare it to the fixtures you have or love to use, and shout if anything’s missing.

For LED colour-mixing sources, there is a little concern about the way such a fixture is defined by having at least red, green and blue emitters of quite tightly defined colour ranges and purity; the spec for the green emitter is a slight cause for concern.

These are all issues that require clarity and a bit more discussion. The same team of people who presented to the EU in May and then submitted the exemption proposal – which includes representatives from PLASA, VLPT, OETHG and the IALD as well as the ABTT – have already started informal discussions through PEARLE while continuing to analyse the documents. Within the EU, the documents now move in to “interservice consultation”, which is when the other EU departments (culture, environment, employment) get to comment on the new draft. After that, the expert groups for the Member States get to work on the draft. The entertainment industry will be continuing, through PEARLE, to talk to DG Energy through this process to achieve the clarifications and, if necessary, changes that are required.

So: we are making progress. Things are looking much better than they did a few months ago. But having got this far, we just need to make sure we keep paying attention and working the details to really make sure that we can continue to get the tools we love (or, in the case of tungsten, can continue for as long as the manufacturers keep making it!)

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