Matt Waring

GLA: Too much of a good thing?

Dave Hollingsbee of Stoane Lighting looks at the proposed changes to the Ecodesign for Energy Related Products & Energy Information regulations, breaking down how these changes could impact the lighting industry, both in the UK and beyond.

For the past two years the GreenLight Alliance has existed primarily with the mission to seek and promote the adoption of the circular economy. Our work aims to help all corners of the lighting industry to make meaningful, informed and fair decisions in the pursuit of more sustainable practices. Today we direct the Alliance’s gaze towards the rapidly progressing proposals for changes to the Ecodesign for Energy Related Products & Energy Information (Lighting Products) Regulations 2021, now including Minimum Energy Performance Standard (MEPS). Or, the draft statutory instrument’s full title: Energy Conservation. The Ecodesign for Energy-Related Products and Energy Information. (Lighting Products) (Amendment) Regulations 2023.

This proposed regulation will impact those putting new product on the market in the UK. Does that affect you? Do you specify lighting for projects in the UK? Do you manufacture luminaires in the UK for the UK market? Do you manufacture outside of the UK and export into the UK? Do you manufacture lamps or light emitters destined for UK manufacturers/market? Are you a wholesaler or retailer who places lamps or luminaires on the UK market?

If the answer to any of these questions is “yes” then this proposal affects you.

What is it?

Essentially, for the UK market it is a light-source efficacy minimum for all light-sources. It constitutes an amendment to Ecodesign and is a two-stage proposal:

Tier 1 (coming into force 15/11/2023) 120 lm/W

Tier 2 (coming into force 01/09/2027) 140 lm/W

From where we sit as an industry in February 2023, that is an ambitious threshold to set by anybody’s reckoning. 

Does the GLA applaud it?

The truthful answer is: “Not as it stands”. 

Members are still getting to grips with the impact of the minimum efficacies (the Pon Max calculation) brought in with the EU Single Lighting Regulation (EU Com 2019/2020) and corresponding (largely mirroring) 2021 UK Statutory Instrument 2021/1095: “Ecodesign for Energy Related Products and Energy Information (Lighting Products) Regulations 2021”. In essence a large number of established “go-to” LED products fell below the new minimum efficacy thresholds established using the Pon Max calculation in the regulation.

At the time, many were caught napping. Indeed it is arguably far too soon since the October 2021 implementation to know of the impacts and to comment informedly on prospects of another raising of the bar so soon, in the UK at least.

One obvious concern is EU/UK divergence. With another set of environmentally motivated regulatory proposals to work with, it is hard to see how this is positive for UK lighting stakeholders or any global light source manufacturers.  

Of course, where we do see similarities between the UK and Europe is in the quest to reduce energy consumption and carbon emissions related to lighting. Noble and urgent aspirations, but at what cost to the UK lighting industry? What cost to manufacturing, distribution, specification and perhaps most importantly the end user? 

What is meant by a light source?

This is a very good question, not as easy to answer as you might expect. It is important, there are a range of lm/W concession allowances for particular categories. To attempt to understand the legal definition in this context: have a read through the draft and UKSI 2021/1095. The wording is confusing in the proposed draft, proper understanding of intent and wording is crucial: on the face of it many light sources may not benefit from any allowances at all.

Concessions

There are allowances for some “light sources”, allowing that light source efficacy below the 120 lm/W threshold (as of this November) or 140 lm/W in 2027.

The concessions are cumulative, so if you have a directional mains light source, higher than 93CRI and under 400lm, perhaps an LED reflector lamp for example, then that ‘light source’ must have a minimum efficacy of 70lm/W under Tier 1, and 90lm/W under Tier 2. 

While the allowances may reduce the targets for lamps, there are no such concessions applicable to other light source types. If for example, the light source happens to be an LED for use in an LED luminaire, whether removable or not, then the allowances do not apply. This means that light sources such as COB, LED array and LED tape do not benefit from allowances and must meet the 120lm/W and 140lm/W minimum efficacies in Tier 1 and 2.

With some research into COB manufacturers, one can see that in particular the very high CRI, warm colour temperatures and lower diameter/lower output LED light sources are going to fall below the minimums immediately, if the regulation is implemented according to the current draft. 

Viability

How viable is it for luminaire manufacturers to bring their product offering into line with Tier 1 rules by November?

Will light source (“lamp”) manufacturers, retailers and wholesalers have access to suitably rated equipment in order to legally satisfy demand?

How viable is it for specifiers to ensure all UK projects procuring after November 2023 and beyond will be compliant with the new minimum lm/W light source rules? Will specifiers know if they are being offered a product with a complaint light source?

Recent Precedent

Is there any market surveillance data from UK or from the EU as to the impacts of recent Ecodesign regulation? Has there been any market surveillance done to provide evidence of compliance? Has there been any research to establish the impact of the 2021 Ecodesign regulation in the UK on energy consumption related to lighting? Is it delivering as intended? What is the feedback from specifiers, manufacturers, retailers and wholesalers in terms of implementation?

Given the scale of impact of recent changes should further steps (such as these proposed by BEIS) not be predicated on learnings from similar previous endeavors?

What opportunities might it bring?

UK manufacturers (and others wishing to export into the UK) are forced to blaze a challenging new trail. If successful and other regions decide to follow, UK businesses may find themselves at an advantage, but acknowledging that virtually all light source manufacturers are based outside of the UK and are manufacturing for global markets, that is not a given. Simply relying on LED manufacturers to support UK specific legislation could be considered more of a risk than an opportunity. 

What are the threats and unintended consequences?

The industry is already aware of the flattening off in lm/W improvements in LED technology. Further reductions in energy are now coming from improved optical design, energy conscious designs and of course, intelligent use of controls. Indeed, previously in building regulations, where controls were used, a lower efficacy is allowed. Furthermore we see from building regulations the application of average building level luminaire efficacy, this allows some consideration and flexibility to lighting designers to use the right light in the right places/applications.

Also, while in-use carbon reduction will always be welcomed, as the UK moves closer to a 100% sustainable electricity grid the emphasis surely diminishes and emphasis shifts more to embodied carbon. Keeping kit in use as long as possible and reducing transportation related carbon. If greater gains can be found here should this be where attention is directed?

The UK does not manufacturer the core building blocks that make up solid state emitters, “lamps” or “light engines”. Are we aware of the intentions of the big players in these markets? Will suitable R&D, or simply inventory, be available that meets the proposed changes to the UK market? I.e., will enough product be available that meets the new criteria? What lead time implications? What differing/new commercial implications? If the UK takes a different road, will others pivot to support it, or will the path turn out to be a narrowing trail?

Successful luminaire manufacture (something for which the UK currently has an excellent record) that meets particular customer demands is a complicated balance of factors. Light source efficacy is a vital one but it is not the only one. It is not even the only one to impact overall efficiency (i.e. in-use carbon), far from it. Then of course there is embodied carbon to consider (see Fig. 2). By inappropriately over-emphasising any one factor, a product can easily become non-viable. There are already metrics in use that arguably drive more holistic environmental improvements on multiple fronts. 

The Lighting Industry Association (LIA) has been heavily engaged on this proposal. As Bob Bohannon, Head of Policy & Academy at the LIA puts it: “The BEIS consultations refer to CLASP and sustainability NGO. Our industry fully agrees with them on the need to deliver net zero, but we differ in how this should be delivered, we think far more energy saving is available via the use of controls and energy effective (scheme) design. CLASP’s Mission Statement is “to improve the energy and environmental performance of the appliances and equipment we use every day, accelerating our transition to a more sustainable world”. Therefore CLASP place supreme emphasis on Efficacy (lumens per watt), whereas looking at Fig. 3 (derived from the US Dept. of Energy, 2019 Lighting R&D Opportunities), you can see it demonstrates all the other factors we need to consider and some of these come with a technical trade off with energy efficiency.

“Our industry is still in the midst of implementing the changes required by two previous sets of regulation – both will significantly help the decarbonisation of our economy. First, the Restriction of Hazardous Substances (RoHS), will largely remove fluorescent lamps (which contain mercury) by early 2024 - this is positive as it will further drive the take-up of low-carbon LEDs. Second, the Ecodesign Regulation changed the energy rating label on lighting products to promote both consumer demand and manufacturer supply of ever more efficient lighting products. 

“In terms of practicable timescales, the latter just impacted labelling, the product itself remained unchanged – yet is likely that in excess of 15 million light sources are still on the market with the old label (the problem is shared across Europe, it is not restricted to the UK). The current legislation will require these to be relabelled for display by retailers by 1 April 2023. This situation has arisen due to the disruptions of Covid-19 and the supply chain crisis - LEDs have semiconductors in them. If this date is adhered to, the unintended consequence will be a large-scale shortage of products and potentially mass dumping at a significant cost. Physical relabelling of products on the shelf across the whole supply chain is not practical or deliverable due to staff shortages and cost. We must emphasise that the product has not changed, it is no less energy efficient, the only change is the energy rating label.

“This is important to understand, as the new MEPS legislation will require complete reformulation of many products, where that is even possible, in seven months, when we have an 18-month replacement cycle. This will result in empty shelves and unrelampable light fittings.

“Tier 1, due to come into effect in November this year, gives insufficient time for the very probable demand pull and supply push effects of those new labels to have had any chance of being effective, nor for any supply chain problems to be resolved – in fact it will exacerbate them.“

The industry has more recently achieved some significant milestones in terms of efficient, long life, very stable, high fidelity solid-state products (think museum and gallery lighting). Similarly, particularly post-Covid; encouraging progress is being made on the light and health front, and in night-sky (nature sensitive) schemes. These, not so niche anymore, areas mostly call for richer phosphor mixes (seeking to approach the light quality of natural daylight or incandescent sources) with correspondingly lower lm/W performance. Are we prepared to surrender some of the progress made in these areas by allowing this regulation to proceed un-challenged?

How does one reconcile a separate sustainability initiative for one small region with the overarching goal of accelerating towards (our collective imperative) consistently reducing the impact of lighting, covering as much of the world as possible?

In forming an opinion it is worth looking into your favourite equipment providers; be they luminaire OEM or LED light engine providers. Better still, speak to your contacts there and establish if they think the new rules would affect product availability, future R&D direction and of course, costs.

It is no secret that the initial efficiency leaps in LED technology have slowed and begun levelling off. Some see the developments in Potassium Fluorosilicate (KSF) phosphor technology as another avenue to surge efficacy, but do we completely understand the areas where we can, or perhaps should not; use that technology yet?

Numerous lighting bodies are mobilising on this issue. If you want to learn more we suggest you also contact your societies, members groups and keep an eye out for on-line gatherings by GLA. We hope the article is useful and informative. Please stay engaged.

www.greenlight-alliance.com

Useful Links:

The full draft document: Energy-related Products Policy Framework

The government’s consultation portal for your input

The consultation document - to have your say, you must submit contributions by 04/04/2023 or be heard at one of their stakeholder events.

GLA Members comment:

Kevan Shaw, ELFA | Kevan Shaw Lighting Design: "I think that Ecodesign for lighting has run its course. Any attempts to increase light source efficiency without reference to particular lighting applications is bound to limit quality of light. Regulations without enforcement penalise the local and quality product manufacturer. Creating different regulatory requirements in the UK compared with the EU disadvantages UK manufacturers, increasing their costs and reducing the availability of products in the UK lighting market – and increasing prices.

What should happen? BEIS should park this proposal and see what happens in the next round of Ecodesign in the EU, then make necessary changes to remain in line with that. Keeping parallel rules makes most sense for the industry, the lighting design profession, and the end-users of lighting."

Leela Shanker, BR+A / GLA LCA Incubator: "On the one hand, it’s encouraging to see the UK ready to flex legislative muscle and set unprecedented, quantitative targets with some degree of urgency - someone has to lead. Though, for decarbonisation efforts to have the most impact, we should avoid a global policy patchwork and include designers and consumers in the solution. Over-reliance on a single efficacy metric (lm/W) that stops at “the Gate” places undue weight on manufacturers’ product design to reduce the industry’s carbon footprint by underestimating the need to revisit how and where we use light. The potential for progress lies in designers working alongside manufacturers in pursuit of globally harmonised standards measured across all phases of a product’s life.”

Emilio Hernandez, Ström / GLA Chairperson: "There are numerous complications as we look into this further. But crucially for me there is no mention within MEPS of how existing or conventional luminaires can be maintained or remanufactured and still meet this ‘light source’ efficiency target. This must be addressed to make the transition more sustainable and affordable and avoid huge piles of WEEE waste in its wake."

Arfon Davies, Arup: "The proposed Minimum Energy Performance Standards (MEPS) within the Ecodesign regulations comes at a time when we urgently need to be focused on what I often refer to as “Beyond Energy”. It is not to say for one moment that lighting energy and operational carbon use is not important, but our focus needs to be on ensuring lighting for humanity is the best it can possibly be. Applying a single efficacy metric to light sources oversimplifies what is a very complex design challenge. It is not helpful as it distracts our attention away from where it should be - careful and informed use of light to create visual environments that promote wellbeing, engagement and generally high-quality experiences for people. The current draft therefore needs an urgent rethink. Amendments would be better focused on promoting higher quality lighting, delivered using circular economy principles, with people and planet in mind, as opposed to driving unrealistic efficacy targets."

Ali Kay, Stoane Lighting: "The proposed regulations place an unreasonable efficacy expectation on LED light sources for use in LED luminaires when you consider the breadth of lighting applications. An unacceptable number of very high quality, high CRI, low CCT, small diameter COBS in particular would be lost with impacts to high quality high CRI lighting, lighting for human health and lighting for use in our exterior environments where very warm LEDs are used to reduce impact on nature. I support the motive to reduce the impact associated with lighting but believe existing regulation has already made big steps on in use carbon reduction and now we must turn to product durability, the circular economy, energy saving through controls and reductions in impact associated not just with the use stage but how we manufacture lighting equipment. If these proposals are to proceed then at the very least, we must see lm/W concessions for LED light sources, such as COB and LED chip arrays on PCBs or many manufacturers will for certain have to remove significant portions of their product offering from the UK market. This inevitably resulting in significant commercial and environmental harm as unused inventory is sent for recycling, with as yet, very little available in the market to replace it."

Alexia Gkika, Buro Happold: "Supply difficulties – if light sources with such energy performance requirements are not widely available, will these lead to extending lead times and supply shortages, impacting project programmes/ costs?"

Tim Bowes, Whitecroft Lighting: "Whether it is through the implementation of legislation, taxation, research or funding, Governments are seen by many as a key and necessary stakeholder in the adoption and development of effective sustainable and circular economy principles at scale. However, whilst we must of course look to continue to push and demand more of ourselves, any intervention must be done in collaboration with our industry. By doing this, we can make sure any future proposal and targets are targeted, workable and achievable so we can maximise the savings available from lighting systems whilst avoiding negative impacts such as a compromise of light quality."

Xander Cadisch, Phos: "We fear that as a consequence of MEPS human centric / biophilic lighting will be, by default, sacrificed for the sake of high output fixtures and the flat, barren design opportunities they offer."

Bob Bohannon, LIA: "I must absolutely state that the LIA is fully behind the need to deliver Net Zero, and we need to do this long before 2050 if we have any chance of limiting global average temperature rise to 1.5C. The method should be based on LENI, ergo energy effective design by the use of efficient luminaires, used carefully to deliver high environmental lighting quality but only when and where we need it. But BEIS’s proposals as they stand have too many unintended consequences and do not allow for existing measures to take effect."

Alan Wright, Xicato: "Increasing efficacy is important but one needs to consider the inverse relationship between brightness and quality.

A colour rendering index (CRI) is a quantitative measure of the ability of a light source to reveal the colours of various objects faithfully in comparison with natural light. Xicato has been one of the first providers of light sources to actually address this and produces some of the world’s best colour rendered light sources; used in a wide variety of markets including, museums and galleries, hospitality, education, medical institutions, commercial and private residences.

With a good colour rendered light source (95+ CRIi) lower efficiencies than those proposed by the BEIS are realised, especially when combined with the smaller beams demanded throughout the industry.

Most higher efficiency light sources will have a high CCT colour temperature to achieve a high lm/W figure and will subsequently provide a poor lit effect, often having a higher concentration of blue light."

---

by Matt Waring