The Single Lighting Regulation

Introduction

The Ecodesign regulations affect manufacturers and suppliers of many things: fridges; vacuum cleaners; domestic and office appliances and, of course, lighting.

The regulation has honourable aims: to reduce electricity consumption in Europe by MASSIVE numbers of terawatts and tonnes of CO₂.

Ultimately driven by the aims of the Paris climate accord, few would think this a ‘Bad Thing’.

Lighting accounts for a large proportion of power consumption, and LEDs have the potential to make enormous energy savings compared to tungsten and most other types of light sources. One day it will be true to say that NO other light source will match the efficacy of LED, and that day will arrive during the lifetime of most of you readers.

The trouble was, and there was trouble, our teeny weeny industry was swept up in this cause with potentially serious consequences for owners of large inventories of perfectly good tungsten lighting instruments. Some of these are mere tin cans and some are precision spotlights with many sophisticated characteristics (and a value to match) and all of this equipment faced obsolescence if the Regulation intended for households, offices and mass-market applications were applied to professional entertainment lighting. Add to that the fact that makers of LED entertainment lighting would often not meet the efficacy requirements (because their lights are SUPPOSED to be stupidly bright, or stupidly narrow beam or some other superlative of performance for art’s sake).

I will try to take you through the Byzantine maze of the Regulation text. The process of writing regulations like this is quite obscure and secretive, and we are left to decode the rationale for the rules ourselves. Be prepared for a headache, and take a length of Ariadne’s thread with you.

Mantra

Remember this mantra: The regulation applies to light sources alone and not to luminaires.

Simplistically, a light source is the moral equivalent of a lamp: the smallest demountable part
that emits light.

This sounds like it should be easy, but wait and see what is in store. In yonder days of yore a lamp was … a lamp! FEL, HPL or PAR, everyone knew what a lamp was. You put electricity in one end and light comes out the other, or so to speak. This regulation attempts to apply this simple idea to the modern world of weird and ever-changing designs of LED and all manner of other light sources. Sometimes this principle works and other times it falls flat on its face.

The ‘Light Source’ means something quite specific: it is the ‘thing’ that emits light with no surrounding equipment or luminaire (no optical train nor any optics at all, not even the micro lenses right on top of the LEDs).

AND

The ‘means to connect to the electricity supply and convert to a format suitable for the light source’ (paraphrase). This is meant to describe the driver.

It’s those two things, always those two things and never anything else in the way, either in the way of the light escaping or ‘in the way’ of the electricity supply – i.e. anything else consuming electricity. We will come back to that later. The regulation demands that we extract only the thing that produces light when attached to the electricity supply and nothing else – exactly as if it were a tungsten lamp from the olden days. We shall see that this can range from quite difficult to impossible to achieve for some types of equipment and guess who makes that kind of equipment? Yes, WE DO!

At the tail end of 2017 our industry was made aware of this looming threat, shamefully late in the process. A team was hastily put together to challenge the EU to consider our special case and not blindly apply rules for household lighting to theatres, film studios and the rest of what we do.

The initial draft regulation spelled the end for supplying tungsten lighting and lamps from September 2020, with no apparent concern for the consequences for entertainment uses. A petition was put to the EU and eventually a meeting was gracefully provided in May of 2018. The result of the encounter was an instruction from the EU to devise a technical exemption and list a set of tungsten lamp bases for exemption.

What follows now are the details of the exemptions and the parts of the regulations that WILL apply to us and discusses a few residual problems which will present challenges, both for us to implement and for the EU to enforce.

Our first achievement is this: the enactment date was moved out by one year. Now this will come into force in September 2021.

Exemptions

• Basically there are seven types of exemption that affect our industries:

  • Lamp base list

  • Absolute brightness

  • Point-source brightness

  • Beam angle

  • Colour mixing ability

  • R7 lamps with high output

  • Standby Power

There is an eighth exemption for certain white light sources used in our industries, but the drafting is faulty and a process is underway to get it corrected.

Lamp base exemption

This exemption is strictly about the type of base and not ANSI or CP lamp codes such as FEL, GKV, CP61 and the like. The rationale is that the EU can monitor this exemption more easily.

Except for the E40 type indicated below, any tungsten lamp on one of these bases is exempted regardless of its characteristics such as voltage, power, brightness, colour temperature, service life and so on.

• G9.5

• GX9.5

• GY9.5

• GZ9.5

• G9.5 HPL

• G16D

• GX16 (PAR)

• GX16D (PAR)

• GY16

• G22

• G38

• GX38

• GX38Q

• P28S

• P40S

• PGJX50

• QXL

• K39D

• E40 24V Crown silver

The DWE (PAR 36 120V 650W) lamp is subject to the aforementioned drafting error and it remains uncertain if it is exempted. The intent is there but the text does not work.

Brightness exemptions

Absolute brightness: All light sources of more than 82,000 lumens or less than 60 lumens.

82,000lm more or less corresponds to 3.5kW tungsten and 1kW discharge. 60 lumens is to exempt indicators. Beware of LED tape, if each cell is more than 60 lumens it is not exempt.

Point-source brightness: light sources with a radiance or surface brightness of more than 500 lumens per mm². In practice, this exempts all short-arc discharge sources and many if not all medium output discharge lamps such as 575 W MSR. No LEDs approach this surface brightness.

Beam angle exemption

Any lamp or light source producing a beam of 10 degrees angle or less.

This should exempt some narrow-angle MR16, PAR36 pinspots, possibly some types of AR111 and aircraft landing lights. If a lamp is sealed with a reflector it counts as being a singular ‘light source’ that cannot be further disassembled. A capsule with a separate reflector would not enjoy this exemption.

Colour mixing exemption

If the source can produce particular shades and purities of the three primaries– red, green and blue – then it is wholly exempted, regardless of any other colours it may be able to produce.

Red = 610 nm – 670nm, 95 % purity

Blue = 440 nm – 490nm, 90 % purity

Green = 520 nm – 570nm, 65 % purity

The Green definition is large and includes a wide range from green to green/yellow and lime. Take care when assessing Lime for this exemption as that color lies right on the edge of the acceptable color region.

Calculating Colour Purity:

• On the CIE1931 x/y colour space find the white point, D65 = 6504 K

• Draw a line to the edge where the wavelength is shown

• Measure the % of purity as a proportion of the line length

• Do for both min and max wavelengths

• Draw a box bounded by the found points

• Repeat for the other colours

‘Colour Tuneable’ exemption criteria:

For the exemption there must be at least one emitter in each box. There can be any other additional emitters anywhere else.

Lime sits on the edge of the green box. It is possible that future phosphor converted red LEDs will also fall outside the definition of red that allows the exemption.

Other industries

Since the beginning of electric lighting for entertainment we have used light sources from other industries:

E.g.: carbon arc, cinema projectors; PAR lamps, warehouse lighting; ACLL, aircraft; Fluo tubes, commercial / industrial.

During our contacts with the EU we were advised that ‘it is not permitted to use light sources exempted for one industry in another’. This will be news to many, but enforcement is a distant prospect.

Exempted industries

Military, Road vehicles, Aircraft, Railway vehicles, Marine equipment, Medical devices and others are all exempted completely. Why are we not also an exempted industry? Some of the answer may lie in an EU perception, based on lobbying of some years ago, that we just wanted to keep our old tungsten way of doing things. The EU clearly fears crossover use between entertainment and mass market products, and with some justification. Anyone can mark their light gadget as a ‘professional entertainment luminaire’ or suchlike. Now, the EU told us their policy was to not give us a ‘sectoral’ exemption – and then exactly the wording we proposed appeared in several places in the final text:

(equipment) designed and marketed specifically for scene-lighting use in film studios, TV-studios and locations, and photographic-studios and locations, or for stage-lighting use in theatres, discos and during concerts or other entertainment events, for connection to high speed control networks (utilising signalling rates of 250,000 bits per second and higher in always-listening mode).

Although this termonolgy covers several cases it is nonetheless not a general exemption for our industries.

R7 lamps

Throughout 2018 we hotly disputed R7 linear lamps with the EU. The original text was illogical and might have given an exemption to exactly the least worthy types, i.e. the lower power types used widely in residential and commercial.

In another last-minute change it was resolved, during the vote, to exempt all R7 lamps of 12,000 lumens or more output, irrespective of their length, power, CCT or other characteristics.

In practice this value corresponds to around 600 W, so all R7’s of higher power are exempted.

Standby Power

Standby power and network standby power are two definitions of the same basic limit.

Until the very day of the vote we were to be affected by the Standby Power requirement. It was exempted for us by application of the text

‘(equipment) designed and marketed specifically for scene-lighting use in film studios, TV-studios and locations, and photographic-studios and locations, or for stage-lighting use in theatres, discos and during concerts or other entertainment events, for connection to high speed control networks (utilising signalling rates of 250,000 bits per second and higher in always-listening mode) shall be exempt from the requirements of Standby Power (Psb) and Network Standby Power (Pnet)‘

It is important to consider the scope of applicability of this phrase. The text defines a product and not an application. If an entertainment light is used to light, say, a building exterior this exemption should apply. Conversely, If an architectural or General Lighting Service luminaire is used to light a theatre stage it is NOT exempted for Standby Power by this text, see below.

Requirements

It’s simple, if none of the exemptions apply you arrive here with these following requirements. There may be trouble in here for some of us, some types of entertainment lighting equipment may fail one or other of these cases. Most of them would have failed Standby Power, but that spectre has been defeated.

Standby Power:

The light source, including the driver, must consume less than 0.5W when no light is being emitted. This requirement is both difficult to meet and difficult to correctly interpret and apply to a product.

The 0.5 W means the part due to the operation of the light source and its driver alone, with all other ‘things’ turned off, disabled or disconnected. Large luminaires cannot comply with 0.5W Standby, but, it is not the luminaire that must comply! It’s the light source!

The regulation expects that all light sources are easily removable, along with their control gear alone, to be measured for Standby Power.

The method of measurement is not defined and in complex lights it is highly impractical to separate the light source and driver. Who is going to make this measurement and how will they know they got the ‘right’ answer? Well, my guess is that the manufacturer will do this, and I imagine they might often get the right answer…

This all leads to what I call the ‘Merchant of Venice Problem’. Fittingly, for the Standby Power measurement, the light source must be ‘cut off from the breast’ of the luminaire without a ’drop of blood’ of the rest of the body being included. Thus would have argued Portia… (Merchant of Venice Act IV, Scene 1).

We are told to ensure that: ‘the power consumption of lighting control parts and non-lighting parts is minimal (if these parts cannot be disconnected or switched-off)’.

What does that mean? Minimal is easy, it’s just whatever the lowest value is found to be (say, 10 Watts,). We can live with that, but I have no idea if that’s what the text means to say.

Efficiency

Now on to the main course: efficacy and efficiency. You can take your pick of terms to use but the issues remain the same.

The minimum efficiency allowed for a ‘Light Source’ (and the driver, remember) is around 75-90lm/W. It is not a single precise value and must be calculated according to:

Where:

P_onmax = Maximum allowed wall-power consumption in Watts.

= Light source correction factor

= End loss factor

_use = Declared useful luminous flux

= Efficacy factor

• = Threshold efficacy

= CRI factor

In case you are inclined to look up these terms, look no further. Most of these are terms invented by EU departments to make the idea work. The values for C, L,  and R are ‘made up’ to match the facts to the goals of the regulation. There is some sense to them, but they are not science. The values are presented in several tables.

Very high output white LED arrays

In large high density arrays three effects reduce efficiency:

The Auger Effect: usually, LEDs are measured for efficacy at a modest current, say, 1/3^rd of the maximum possible current. When driven to three times this current, to the maximum possible, the output does not increase by three but only by around 80% of 3. i.e. 2.4 times. Put another way, the light source is 20% less efficient at maximum power.

High temperature: at the highest outputs arrays are driven into the highest allowable temperatures. Output also diminishes with rising chip temperature.

Losses in inseparable optical elements: for modules it may be hard or impossible to isolate the light source from its integrated optics. This popular light source used in moving lights and long-throw spotlights contains four lenses, so eight surfaces where optical losses occur. These losses further diminish the efficiency by around 15% or more. Although exceptionally bright and good at directing light to an aperture in a spotlight, these types of modules, if measured as a finished unit cannot meet the minimum efficacy requirements. If they are disassembled down to bare LEDs they will most likely comply, but doing so damages the light source (by breaking the gas-tight seal) which is unintended by the regulation.

Loopholes – waiting to happen

Battery vs Mains: is a lamp used both in battery and mains luminaires exempt or not? Battery powered lighting is exempt and mains is not, but that lamp may be the same lamp!

Image capture: lighting for ‘image capture’ is exempted. Examples are given such as ‘photocopier lights et cetera’ the et cetera opens a Pandora’s box of conflicting interpretations. Could this term be argued to include lighting for photography, TV and Film? Perhaps it could, there may be a precedent.

Image projection: lighting for ‘image projection’ is exempt. Examples are given such a video projectors. Is a spotlight with an electronic gobo an image projector? It seems to me that it is.

Plenty more legal fees lurking in that lot.

Conclusions

Nearly everything we use is exempted in one or another way.

Several problems remain, particularly in the Annex II Clause 2(w) which is intended to exempt the following cases:

Professional entertainment light products (defined by the description shown earlier), which are also:

• LED and CRI >90

• LED modules above 180 W power arranged to direct light to an area smaller than the light emitting surface. (such as the module described above)

• Variable white LED

OR

• DWE 120 V 650 W PAR36 lamp type

OR

• T5 or T12 Fluorescent with particular CRI and CCT characteristics, again, of the sort used in professional entertainment.

An error appeared in the drafting of this clause rendering it mostly senseless.

What next?

Five years. That’s all we’ve got… In five years some of these exemptions may be withdrawn, and the current version actually states that intention.

Finally, a closing remark: do not imagine that the list of exempted lamp bases automatically means that factories will carry on making these types. There are fewer and fewer players in the tungsten lamp making business and this will further decline as the economics of mass production go and only our meagre market is left for them. Prepare for the end of tungsten, even though we have an exemption for the time being.