Orgalim notes of the ecodesign stakeholder meeting on the Ecodesign and Energy Labelling Regulations on light sources of 19 February 2020

In the chair: Robert Nuij, DG Energy

Participants: member states (, , the , Spain, Croatia, , Germany), industry (Lighting Europe, Orgalim, APPLIA), ECOS, CLASP, Swedish Energy Agency, ANEC/BEUC

Meeting summary: The Ecodesign and Energy Labelling Regulations on light sources, (EU) 2019/2020 and (EU) 2019/2015 were adopted in 2019. Following the adoption, impacted stakeholders reached out to the (EC) pointing out to some concerns related to the regulations. The stakeholder meeting addressed the issues of concern such as stroboscopic visibility measure requirements, the ecodesign regulation’s scope and certain energy labelling requirements. Following the meeting, the EC would decide whether the regulation needs to be revised or amended. A formal consultation forum is expected to be organized as well.

Robert Nuij welcomed the participants to the meeting. He said that the EC had adopted a number of ecodesign regulations, including the Ecodesign and Energy Labelling Regulations on light sources, a year ago. Since then, the EC has been contacted by several people, arguing that the adopted regulations might cause some concerns. The meeting focused on stroboscopic visibility measure (SVM) requirements for mains LED and OLED light sources; potential exemption for clear heating lamps and certain aspects regarding labelling of light sources.

Presentation of potential issues and discussions

1. Stroboscopic visibility measure (SVM) requirements for mains LED and OLED light sources

This issue was introduced by Małgorzata Perz, on behalf of Lighting Europe:

• She presented the development and validation of SVM • Constant light vs electric, modulated light • Presented the difference between flicker and stroboscopic effect-unnatural break-up of motion • A number that tells whether the stroboscopic effect is visible or not: SVM>1 is visible, SVM=1 is just visible; SVM < 1 is not visible. • Measured acceptability of SVM-people find some level of stroboscopic effect acceptable. Results of 5 acceptability studies show that slightly visible stroboscopic effect is acceptable in general illumination applications, like an office

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• SVM between 1 and 1,5 is acceptable. SVM between 1,5 and 8 is not acceptable. • Experiments conducted, showing no health effects from moderate SVM. • Conclusions:

o the stroboscopic effect is caused by the AC mains power; The effect is the unnatural break- up of motion; o SVM is developed to predict the visibility of the stroboscopic effect; o The visibility threshold of SVM is 1 by definition; o The stroboscopic effect can be slightly visible and still acceptable; o A long-term study shows that SVM ≤ 1.34 (at least – higher values were not tested) did not cause health problems (eyestrain, headache). o SVM is not predicting health-related issues.

LED lamp design options and constraints for limiting SVM (what does applying SVM to technology actually mean?)

• One option is to increase the size of electronics; efficiency of the driver goes down, generating more heat; another option to change SVM relates to how we draw the energy from mains power. • three ways to lower SVM values for LED retrofit lumps identified. The speaker introduced characteristics, modifications for SVM requirement and consequences and limitations per each of the options. o 1st-sipmle single stage topology with an input capacitor; 2nd option is a single stage topology with output capacitor; 3rd option-single stage topology with output capacitor and ripple reduction circuit • Impact of 3-5% efficiency decrease of the driver will locally lead to 30% higher losses. • Conclusions: The combined consumer and professional LED lamp categories incorporate thousands of different lamp types. Each lamp category contains multiple product ranges e.g: luminous flux, lifetime, color, efficacy, beam shape, outline and materials (full glass, glass/plastic, full plastic). Retrofit LED lamp designs are restricted by thermal system constraints (Examples: G9, GU10, R7s, T5, E14, E27 and E40 high power lamps). Driver solutions to limit SVM to 0,4 are feasible. Driver solutions to limit SVM are not feasible for all LED retrofit lamps for the consumer and professional product ranges.

Lighting Europe (LE): LE is concerned that 6 LED lamps will be out of the market due to the new SVM< 0.4 requirement. LE request to raise SVM to 1.6. Their concluding remarks:

• No evidence to date of health effects from moderate SVM; • Results of testing made by LE and by Swedish Agency demonstrate that there are mains LED light sources (as well as many mains conventional light sources) that do not comply with the new requirement of SVM; LE advises regulators to revise the SVM requirement, taking into account:

• Possible for some products does not mean possible to total range • technical problems include: lower light output & efficiency, cap size is too small, heat problems, lower lifetime & reliability, bigger outline so no fit in existing luminaires; • LE continues to remain available to test light sources already tested by other experts in order to compare results delivered by different laboratories - assuming the legislative timetable allows this.

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Swedish Energy Agency (SEA): There is a need to have product requirements on temporal light modulation (TLM) for consumer protection. Pst and SVM have been proposed to be included in new requirements. SEA presented the study that explored whether products are available that already now meet the upcoming requirements on 1st September 2021.

SEA presented a list of different lamp types that compile with the new SVM requirement. In conclusion, SEA finds products in all 6 categories of LED lamps that align with the future requirement. Relaxing SVM to 1.6 wouldn’t change the outcome in this study very much. Further, the study did not find obvious correlation between SVM and EMC performance. SEA also investigated driver designs. Found very little extra cost for a proper driver design.

Summary:

• products available on the market that already meet Pst and SVM requirements two years before the requirements coming into force; • Increase SVM level from 0.4 to 1.6 would have limited impact; • Driver design: virtually no extra costs for proper design. A discussion followed on whether an additional testing would bring an added value since it would require more time. The participants argued that testing would bring more data and help creating a better picture of the current situation and help the EC to come up with alternatives to the existing text. The EC agreed and invited the participants to conduct testing within the next 2 or 3 months.

“The EC will look at all regulations to see whether we need to propose amendments. We will have to go through the normal process, which is making a draft proposal and sending it to a consultation forum. We would give you a month to respond. An IA process is not envisaged. After the CF, we will submit the proposal to the WTO and to the regulatory committees for the ED measures. We still can meet that deadline regarding the measures entering into force on 1 March 2021”, said Robert Nuij.

2. Potential exemption for clear heating lamps and certain aspects regarding labelling of light sources

Lighting Europe argued for an exemption request for E27 infrared lamps (clear types) in ecodesign requirements. • Heating lamps-infrared in many cases, subject to a couple of regulations. 95% of energy is used for heating, and only 5% for light. LE requests to put them back in the list of exemptions under the new ecodesign regulation on light sources. o France strong reservations regarding change the scope of regulation. suggests adding them in the local heaters product group. • Proposal to amend regulation 2019/2015 on the energy labelling on light sources: regarding a new requirement on labelling colour- LE requires to print the label in black and white. EC-invariable parts are in colour, variable in monochrome. ECOS-colours have a very powerful impact on consumers; important to keep colours. Not in favour of monochrome labels. • The packaging shall not be smaller that 20mm wide and 54 mm high-LE believes that packaging should not be regulated, since it depends on the product. If we create bigger packaging-generate more waste, extra materials in packaging. The EC replied that this requirement is not against the packaging directive. The consumer needs to have a label reasonably visible on the packaging. ECOS-

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a balance to be found, not in general for extra packaging, but here there are different reasons for doing that.

3. Potential clarifications needed in the legal text

• Definition of light source in the ED and EL regulations- o BAM (German senior scientific and technical federal institute) argued that there are some ambiguities on the definitions such as ‘containing product’-the definition is contradictory as that contains only a separate control gear which cannot be taken apart from verification is a light source. Member states disagreed with this interpretation. Suggestion to make the wording clearer. o Definition on a product containing two light sources-BAM argued that if the luminous flux of the containing product above 82000 Im but the single light sources have fluxes below this value, the product would not be in the scope of the regulation. Further, an exception of HID is not necessary. Required to specify which information should be displayed on a chip on board. Reacting to the presentation on ambiguities and inconsistencies in the new regulations, Robert Nuij said the EC would like to keep a number of changes/amendments to a minimum. “Sometimes manufacturers do not read carefully some regulations”. APPLIA also intervened during the meeting, as the current regulation’s wording renders manufacturers of household appliances with the same status as manufacturers of light sources. They argued that:

• Household appliance main purpose is not lighting; • Manufacturers of household appliances might implicitly become manufacturers of light sources- which in principle we are not. For example, in the lighting regulation they become suppliers of light sources since they are importing components; • Definitions of light source and containing product contradict each other. According to the definition of containing products, an appliance can become alight source. How to handle this obligation? • Several other contradictions regarding for example removability requirement for verification, definition of control gear.

To wrap up the meeting, the EC’s representative asked the participants to send their written feedback by mid-March 2020, highlighting that “This is not a formal consultation forum, which will be organised as well.” The EC will decide which issues need to be addressed. The EC underlined that it has not yet decided whether to do a revision/amendments. It is quite likely that the service in charge would come up with some proposals for amendments.

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