The new EU Ecodesign Order
In late 2019, following long negotiations, the EU published its new ecodesign directive, aiming to raise standards of energy efficiency in electrical products across Europe. In an interview for BTR, technical director Hans-Joachim Rau talked to light expert Christian Allabauer about what the new regulation means for the events industry.
The limits of the new EU directive on “ecodesign and energy labelling – light sources and separate operating devices”, due to come into force in September 2021, tightens regulations for lights and separate control gears.
It is based on the EU’s ecodesign directive, which lays down the requirements for the environmentally friendly design of “energy-related products” in Europe’s internal market. The original bill threatened a major incursion into theatre-related work. Most of the light sources used in the events sector would no longer have been legally available for purchase. But some determined arts workers fought their way through the EU’s legal jungle, confronted the committees with clever argumentation, and saved our lighting world. One of those involved in the debate was Christian Allabauer, head of a team of specialists on lighting in the Austrian stage engineering society OETHG.
Hans-Joachim Rau: Mr Allabauer, the new ecodesign order is the result of efforts to save energy. Does that mean that energy efficiency and light quality are necessarily conflicting interests?
Christian Allabauer: We all want cars that use less fuel and that means keeping them as light as possible. But airbags and electronic driving aids make them heavier. So, the weight of cars can only be reduced within limits that ensure their essential functions (e.g. regarding safety) are maintained. Similarly, we should try to optimize energy efficiency in stage lighting within the bounds of ensuring the required light quality is achieved.
It’s mainly a matter of efficiency, then?
Yes, essentially, the order is about ensuring the best possible efficiency for the largest possible number of light sources. If you go beyond the basic requirement of ‘creating visibility’, it is striking that the directive only balances a part of the use (the luminous flux emitted) against the total resources needed (electricity output). But to work out a realistic level of efficiency for the industry, all aspects of use (for stage lighting, that means even spectral distribution, desired light diffusion, high power density, low-noise operation, compact size, capacity to satisfy artistic demands) need to be considered and factored in.
What will be regulated under the directive?
The directive applies to light sources and “separate operating devices”. It is only concerned with electric light sources that emit more than 60 Lumen (no indicator lights) and less than 82,000 Lumen (no halogen lights over 5kW or discharge lamps over 1 kW), or emit an emission surface area of less than 500 Lumen per square millimetre (many discharge lamps) or ‘whitish’ light (by a black body radiator’s curve) and are not subject to any exceptions. Separate operating devices process the mains voltage so that it can be used by the light source. Even light sources that are put on the market built into spotlights come under the provisions for light sources.
What happens when a non-standard quality is required?
If a light source is required that is especially bright, compact, quiet, or ‘colour-fast’, it can’t be achieved under these energy efficiency requirements and today’s technological standards. The European legislation achieves this state by limiting the area of application and maps it with exceptions – e.g. for the medical service, the military, and transport.
Do all LED light sources and spotlights meet the energy efficiency requirements?
In foyers, offices, workshops and auditoriums, the requirements must and can be met. Very many such spaces have already changed to LED lighting. The technical requirements for stage lighting, however, mean that some of the energy is consumed by the light sources’ special properties, and they are not optimized to high luminous efficiency. For this reason, even LED light sources don’t meet the standards set by the directive for the bulk of our uses.
Which concessions have been made to the events sector as a result of negotiations with the EU?
The following lights, which were originally set to be discontinued under the directive, can now still be marketed as exceptions to the rules:
Halogen lights: exceptions conceded are stage lights using one of the following bases: GX9.5, GY9.5, GZ9.5, GZX9.5, GZY9.5, GZZ9.5, K39d, G9.5HPL, G16d, GES/E40 (only low-voltage (24 V) bowl reflector lamps), GX16, GX16d, GY16, G22, G38, GX38, GX38Q, P28s, P40s, PGJX 36, PGJX50 and R7s with a luminous flux of > 12,000 Lumen and QXL.
Colour-tunable light sources (CTLS). That applies to LED light sources with light composed of individual colours (RGB+) and which can provide red, green and blue light over a specified wavelength range and a specific repletion.
Point light sources with a half peak diversion of under 10°.
High performance white light sources. The current text of the directive is inconsistent, encompassing LEDs with CRI>90, which have either >180 W and a gate (LED moving heads with high CRI) or two white tones for different colour temperatures. But especially in live entertainment, spotlights with low CRI but high light output and concentration are required. The text still needs to be amended here. Some special requirements of the film industry also need to be considered.
Stand-by output. Integrated light sources and operating devices with DMX or ethernet connections are exempt from the 0.5 W restriction on stand-by output as they need to be constantly available – the light needs to go on the instant the button is pressed.
How are manufacturers responding? Will their lights not only be permitted but also available in future?
As the legal parameters are now fixed for the coming years, the next step is to talk to the manufacturers. Even if the range of products eventually shrinks, we have just gained the extremely positive assurance that a broad spectrum of entertainment lights will continue to be available.
What qualifies as ‘entertainment lights’ in this context and do these exceptions also apply to related sectors, such as architectural lighting?
Several exceptions only apply to stage light sources and operating devices. These are defined as: “…specifically for scenery lighting in film studios, television studios and at shooting locations, as well as for photographic studios and photographic locations and for stage lighting in theatres, discotheques, concerts and other entertainment events.”
To read the complete text of the final directive, go to tinyurl.com/quozfja
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