Monday, 30 March 2009

5. EU CFL FAQ

No lighting blog is complete without a CFL FAQ page. In this case it comes from a recently issued EU CFL FAQ defending the decision to phase out incandescent light despite the many problems and drawbacks with CFLs.

It is a very long list of concerns and complaints they have seen necessary to address, so I'll only quote and comment some of the most relevant points here (not necessarily in original order). Surprisingly, EU actually confirms the crucial points I've described in this blog (CFL light loss, misleading conversion charts, poor power factor, heat replacement effect etc) but still defends the CFL.
Compact Fluorescent Lamp issues

EU FAQ Question: "III.3. Is it true that compact fluorescent lamps produce less light than incandescents?

EU FAQ Answer: "Compact fluorescent lamps can produce just as much light as incandescent bulbs. Consumers should check the product packaging to buy lamps of the appropriate power and light output. Currently, exaggerated claims are often made on the packaging about the light output of compact fluorescent lamps (e.g. that a 11-12 Watt compact fluorescent lamp would be the equivalent of a 60 Watt incandescent, which is not true)."
My comment: Correct. And this means that CFLs do not save "up to" 80% energy as is often claimed.
"The regulation will introduce restrictions on equivalence claims made on the product packaging, in order to keep the claims reasonable. Until then, for guaranteed satisfaction, a simplified method could be used to compare wattages when selecting the compact fluorescent lamp, by applying a 1:4 ratio (example: the light output of 15W compact fluorescent lamp is slightly more than the light output from a 60W incandescent). Even with this conversion ratio, compact fluorescent lamps are much more energy efficient than incandescent bulbs."
Correct (just as I've been saying, see Conversion Charts). Good to see EU suddenly having realised this (after the ban was voted through on the premises that CFLs save "up to 80%"). After this insight, I expect to henceforth never again see the "save 80%" or "give 5 times more light" in an EU document.
"Nevertheless, it is highly recommended to consider the light output of the lamps instead of their wattage if you want to compare them. It is this quantity (expressed in lumens on all lamps from 2010) that really describes the performance of a lamp, therefore it allows direct comparisons without a need for conversion. For example, a 15 W compact fluorescent lamp typically provides 799 lumens of light and a 60 W incandescent lamp 710 lumens. See also III.9."
This is good advice and I hope it will become mandatory information on the package so as to make this comparison possible for consumers.

Life Span

"III.4. Is it true that compact fluorescent lamps have a much shorter life time than generally claimed?

"Untrue. There are indeed low quality compact fluorescent lamps that do not reach their normal life time (6000 h), but most respect the claimed values in average domestic use. The regulation introduces requirements on lifetime so that national market surveillance can eliminate free-runners."

Many of the best CFLs have gotten better in this regard, if the right CFL type is used in the right luminaire so they don't get overheated etc. But there are still a lot of CFLs out there which, for various reasons, don't last as long as claimed (see Life Span).
Light Loss

"III.10. Do compact fluorescent lamps lose light as they age?

"It is true that during their long lifetime, compact fluorescent lamps will gradually emit less light than at the beginning (incandescent bulbs lose light too, but because of their short lifetime the loss is less noticeable)."

Manufacturer catalogues do not mention this so I've called and asked. Sylvania claim their incandescent bulbs lose no light, Osram says around 5%, Philips Lighting says theirs may lose 5-10% but that they don't last long enough for this to be noticable.
"At the end of their life, compact fluorescent lamps often lose 30% of their initial light. This is why the regulation requires that when claims are made on the packaging of a compact fluorescent lamp concerning equivalence with an incandescent bulb (see III.3), the light output (and power) required from the compact fluorescent lamp is overstated. This way the user will get initially more light from the compact fluorescent lamp than from the incandescent bulb that is claimed to be equivalent to the compact fluorescent lamp on the packaging."
I'm assuming this means requiring packages to recommend a 1:4 switch instead of 1:5 (as stated under III.3 above). A good start, but since an 11-12W CFL gave less light than an incandescent to start with, even using a 15W is often not quite enough when light loss is taken into consideration. To stay on the brighter side, a 20W CFL may be more appropriate for the European market = 1:3 switch (see Conversion Charts for more details).
"The regulation also introduces a minimum requirement on light output at the end of life of the lamps. Nevertheless, over its life, the light output of the compact fluorescent lamp may decrease below the light output of the "equivalent" incandescent bulb. Most users should not notice the difference, those who do will have the option of replacing the compact fluorescent lamp earlier than its normal end of life."
Which makes its practical lifespan shorter than claimed (the industry uses something called "economical life rate" which differs from actual life rate) and thereby also alleged savings.
"III.5. Is it true that compact fluorescent lamps should not be switched on/off frequently because it shortens their lifetime? For example, does it make sense to install them in a toilet which is used for 5 minutes 10 times a day?

"This functionality is also addressed by the regulation, requiring that compact fluorescent lamps should reach the claimed life time while being switched on/off once for every hour of operation. Where frequent on/off switching is likely, dedicated compact fluorescent lamps that can endure up to 1 million switching cycles"

In other words, this is a problem, and if one wishes to conserve energy by not leaving lights on, one has to buy a specially dedicated (and no doubt extra expensive) CFL that can tolerate a million switches?

Osram, for example, says their Dulux Long Life and Facility are designed to withstand frequent on-off-switching, whereas their standard CFLs need to stay switched on for at least 3 hours at a time and should only be switched on a couple of times a day in order to last 6000 hours, otherwise their lifespan may be drastically shortened! (Which might explain why some CFLs last only a fraction of their promised life for some consumers.)

This does not sound very energy saving since the best way of conserving some of those few % energy that lighting uses, is to turn it off when leaving the room (or use an occupancy sensor that does this automatically). Since most people probably buy the cheaper standard CFLs and are either not informed at all of this limitation, or unwilling/unable to pay extra for CFLs that don't have these restrictions, the practical lifespan of the average CFL can be considered much shorter than advertised, and potential savings will of course dwindle accordingly.
"…or other energy saving light sources insensitive to switching can be used (such as halogen lamps which will also remain available)."
Yes, halogen lamps do not have the many limitations and huge quality variations that CFLs do and would be an excellent alternative in many cases. But most halogen lamps will be phased out too, starting with all frosted halogen lamps in September.
Other CFL Limitations

"III.11. Is it true that compact fluorescent lamps do not work in cold temperatures?


"A standard compact fluorescent lamp will indeed lose a substantial part of its light output in cold temperatures. However, there exist compact fluorescent lamps designed specifically for outdoor use which can withstand cold temperatures without losing performance. Consumers should watch out for this information (required by the regulation for display on the packaging) when purchasing compact fluorescent lamps."

Another detail consumers need to educate themselves on and watch out for. And pay extra for, of course.
"Improved halogen lamps will also remain available and can operate in any ambient temperature."
Yes, those few low-voltage halogens that will still be permitted after the phase-out period. This is one more reason halogen lamps should not be regulated. They don't have the many limitations that CFLs do.
"III.6. Is it true that compact fluorescent lamps cannot be dimmed?
"Untrue, there are compact fluorescent lamps on the market that can be dimmed, and there are dimmers that can dim any compact fluorescent lamp."
Both of which are much more expensive and may yet be harder to find. Besides, dimming a CFL will not save any energy, only make the light even more grey and dull than it already was. Standard CFLs still can't be dimmed at all.
"Consumers should carefully read product information concerning dimmability."
Correct. One more thing consumers have to educate themselves on besides finding out which CFL type a) can't be used with electronic timers, occupancy detectors or ceiling fans; b) won't work or give less light at cold temperatures, c) will give less output and die sooner in closed luminaires, d) will give too few lumens compared to the recommended incandescent equivalent; e) will or won't give the colour temperature desired, besides reading consumer tests to find out which brands and models will be more likely to give as much light as promised and last as long as promised (if used correctly).

This will be a requirement for each of EUs 500 million citizens if they want to get what they think they're paying for, since the only reliable and good quality options will be phased out.

"Improved halogen lamps will also remain available and provide full dimmability in all circumstances."
Only clear halogen retrofit bulbs with infrared coating and integrated low-voltage transformers (hardly on the market yet and even more expensive than standard halogen lamps already are) will be permitted after the phase-out period. As all frosted halogen retrofit lamps, including Halogen Energy Savers, will be banned from September, this doesn't leave consumers a lot of choice when it comes to an incandescent alternative.
"III.7. Do compact fluorescent lamps really take longer to switch on and warm up to full light output than incandescent lamps?

"True. In order to guarantee an acceptable level of service with any compact fluorescent lamp, the regulation introduces minimum requirements on switch-on and warm-up times. Switching on a compact fluorescent lamp shall not take more than 2 seconds, and it should reach 60% of its full light output within one minute."
60% within a minute? But what if one wants 100% immediately? (Like one gets from those incandescent and halogen lamps now being phased out...)
"However, there are now compact fluorescent lamps on the market that come close to incandescent bulbs for these performance parameters from the point of view of the average consumer. If these are features consumers are concerned about, they should look out for the information on the product packaging, where the manufacturers will be required to display warmup-times."
Ah, another vital piece of information the consumer will have to search for! And probably pay extra for. And these still won't reach 100% instantly, since that's not possible with CFL technology.
"III.9. Is it true that compact fluorescent lamps do not always fit in the luminaires housing incandescent lamps?

"Compact fluorescent lamps exist today in many sizes and shapes to replace incandescent bulbs. Where there is indeed too little room for any compact fluorescent lamp to fit in, improved halogen bulbs could be used to replace incandescent bulbs."
Which may be too hot or glaring and are not always the most appropriate option even if they give an equivalent high quality light. And low voltage halogen is often somewhat whiter.
Power Factor

"III.16. Compact fluorescent lamps cause losses in the electrical distribution grid due to a poor power factor. Incandescents do not. Is this taken into account when assessing their energy efficiency?

"According to the technical study ordered by the Commission to prepare for the regulation on household lamps (http://www.eup4light.net/) even if we assume they have a poor power factor, compact fluorescent lamps are overall much more energy efficient than incandescents."
Translation: "Yes, we have been made aware of this uncomfortable fact, but since CFLs still save something, it doesn't matter if it's 50% rather than 80%."
"Besides, the regulation on household lamps requires a minimum power factor for compact fluorescent lamp lamps."
So all lamps with below PF 0.85 will be banned from September...? Or just a similar recommendation as for Energy Star: a minimum of 0.5 in order for manufacturers to get the EU energy label by claiming to pass this generous requirement? Which means that such a CFL will use about twice as much energy as is marked with (see Power Factor).
Heat Replacement Effect

"III.17. Incandescent bulbs produce a lot of heat, compact fluorescent lamps much less. When compact fluorescent lamps replace incandescent bulbs in a room, does the increased heating need in the room negate the energy saving through the lower consumption of lighting?
Here we get all the standard counter-arguments (see Heat Replacement Effect) listed together:
"Though it is accepted that incandescent lamps emit heat, incandescent bulbs are not an efficient way to regulate indoor temperature."
And I repeat that people don't use lights to regulate indoor temperature but to see what they're doing.
"The location on the ceiling is inefficient"
Invalid argument since heat circulates and most homes have lights lower down in the room.
"electrical heating itself is inefficient compared to other forms of heating (e.g. gas or heat pumps),
Correct, but see above about people using lamps for seeing, not for heating.
"the heating is unnecessary in the summer period and may even result in increased cooling needs, and not all rooms needing lighting need also heating. Because of all these factors, heat from lighting is considered as energy loss rather than useful energy."
In the summer it is usually lighter so less artificial light is needed. And studies on the heat replacement effect have taken seasonal variations and other factors into consideration when making their calculations.
"Nevertheless, when it comes to quantifying the improvement potential of the switch from incandescent lamps to compact fluorescent lamps, the UK Market Transformation Programme recommends using correction factors [3], to take into account what they call the "heat replacement effect". But even these factors remove only 20 to 30% of the estimated savings in energy costs and CO2 emissions, meaning that the balance of savings achieved is still substantial both for the consumer and for the environment."
Hm, let's see what the study referred to actually says:
"The magnitude of the heat replacement effect for lights in a typical UK dwelling"

"Comparing cases 2 and 3 shows that for the dwelling simulated in this study, 0.363 MWh/yr of electricity is saved by replacing tungsten lamps with CFLs. Because of this, the annual heat requirement increases by 0.220 MWh/yr. This implies a heat replacement factor of 60.6%. However, an allowance should be made for lighting energy used in external lighting. The factor fin (95%) is therefore applied, leading to a heat replacement factor R of 57.6%.

"In terms of delivered energy savings, assuming a 70% efficient gas heating system provides the extra heat, 100% / 70% = 1.429 times the quantity of missing heat from lights will be required to heat the dwelling to the same level. Using the formula from [1] the delivered energy saving factor is thus 17.7%. In other words, only 17.7% of the gross delivered energy saving will be achieved in practice.

"In terms of fuel costs, replacing tungsten lamps with CFLs reduced electricity consumption by 0.363 MWh/yr and increased space heating consumption by 0.220 MWh/yr. However, since electricity is more expensive than gas (by a factor of about 4 in the UK), the gross cost saving will not be so heavily reduced when including the effect of heat replacement. In this case, 84.4% of the gross cost saving will be achieved.

"Similarly, in terms of carbon savings, because electricity is significantly more carbon intensive than gas in the UK (by a factor of 2.2), the gross carbon saving is not as heavily reduced when converting to a saving net of heat replacement. Simulation cases 2 and 3 suggest 61.4% of the gross carbon saving will be achieved."
[emphases added]
Interesting way of focusing on cost and CO2 and conveniently omitting the part about "only 17.7% of the gross energy saving will be achieved in practice". (And in this simulation they have of course calculated with maximum claimed savings for CFLs, as pro-CFL studies always do.)
"The improved retrofit halogen bulbs that will remain available only provide 25-45% energy savings compared to incandescent bulbs (whereas compact fluorescent lamps save up to 80%), which means they still radiate much of the energy they use as heat rather than light."
But the above study just confirmed that this same heat helps keep heating bills down in the UK and cooler climate countries. And CFLs still don't save "up to 80%" - especially not with heat replacement effect taken into consideration!
Light Quality

"III.8. Isn't the shape of compact fluorescent lamps ugly and do they not produce unpleasant light (also in terms of colour rendering, colour temperature and light spectrum)?

"Consumers usually find modern quality CFLs perfectly suitable for everyday tasks and aesthetically pleasing."
No they don't. True that many men don't seem to notice a difference, but then men often have poorer colour vision than women (but better night vision). Most women I've asked or read comments from - and quite a few men too! - do not like fluorescent light or CFLs at all due to the unnatural looking light even from the 'new and improved' top brand lamps. (Yes, this is anecdotal but so is the EU claim to the contrary.)
"There may be some substandard compact fluorescent lamps on the market, but those will be removed through the functionality requirements of the regulation."
But according to recent Swedish consumer tests, over half of the CFLs tested still had a strange colour. And even the most incandescent-mimicking good quality 'warm-white' CFL with double envelope still has a pinkish tinge that might be acceptable in a shaded luminaire but looks distinctly fluorescent and sterile in open luminaires where you see the lamp (or part of it). As this type will be the only frosted retrofit lamp available for open and task luminaires after September, I predict a lot of unhappy customers.

The CRI around 80-83 (medium-good colour rendering) for standard lamps has been the same for decades and will not improve since that means adding more expensive rare elements (which have to be mined out of the ground; not exactly improving the environment).
"Improved halogen lamps will also remain available and produce exactly the same light quality as incandescent bulbs."
Correct about quality, incorrect about availability (see previous comment above).
"Overall, the perception of shape and light quality is quite subjective, however there are parameters that can be measured. On some of these parameters, CFLs are actually doing better than incandescent bulbs and halogens."
This is a direct lie. Not even manufacturers' own catalogues or anyone in the lighting business claim such a thing. CRI values (= colour rendering properties) are always highest for incandescent & halogen light, and spectral power distribution charts show why this is so (see Light Quality).
"Modern CFLs come in a variety of sizes and shapes approaching that of incandescent bulbs. The outer lamp envelope that hides the small twisted lighting tubes has become commonplace, and makes CFLs resemble frosted (non-transparent) incandescent bulbs in appearance."
Correct, except the resemblence is only in shape, not in light quality. Though due to the bigger base they don't always fit in existing luminaires, especially not the candle type CFLs. And the smaller/lower watt CFLs often have poorer performance and durability.
Colour rendering

"In order to ensure proper colour rendering (ability to reproduce the colours of the objects lit) for CFLs, the draft regulation introduces a minimum requirement on this product parameter."

Which I assume is the same as the current standard of CRI 80-83?

Unless the minimum is set at CRI 95-97 (which improves colour rendition but reduces light output by about 30% and makes it many times more expensive due to use of more phosphors), and poorer quality CFLs will be banned, this sentence only means that EU deems medium-quality light in exchange for top-quality incandescent light an acceptable lower standard for EU citizens.

Unfortunately, the lighting industry have created a lighting standard where CRI around 80 is called "good" when in reality it's only mediocre. Anyone who has bought a fabric or chosen paint or wallpaper under standard fluorescent lighting in a shop, only to later find it a different shade than they thought they bought, will know the importance of perfect colour rendering - like you get from natural daylight and from incandescent light.
Colour temperature

"CFLs can be produced with different colour temperatures (warm/cold) depending on consumer needs, whereas incandescent lamps can only provide warm white light."
As stated earlier, special incandescent and halogen lamps come in different colours too, and LEDs come in even more colour varieties, so this feature is not unique to CFLs.

"The draft regulation requires the indication of colour temperature on the lamp's packaging, so consumers should watch out for this information."
Good. But colour temperature for non-glowing light sources is only an approximation when compared to a blackbody radiating light source such as an incandescent lamp. It may or may not look like real daylight or incandescent light, depending on the quality of the CFL and relative success in mimicking the real thing. All too often it does not look quite like the original.
Light spectrum

"The light spectrum of incandescent bulbs resembles that of natural daylight in that it is a continuous curve with no abrupt changes across the spectrum of colours. On the other hand, natural daylight is as strong at the blue and ultraviolet wavelengths as at the yellow and red wavelengths, whereas light from incandescent bulbs has very little blue component and an extremely high proportion of red and infrared component (therefore their light is very yellow and most of it is emitted as heat)."
Correct. Incandescent light (at wattages normal for indoor use) is like sunlight towards sunset. This warm golden-white light is often preferred for home use and makes people and natural materials look their best. This is why manufacturers have tried to copy it in CFLs (with varying degrees of success) and why people are clearing the shelves to stock up on incandescent lamps. And despite being warm in tone, the incandescent spectrum includes enough blue to make blue colours fully visible - unlike fluorescent light which doesn't let the eye see all wavelengths due to spikes and gaps in the spectrum.
"Compact fluorescent lamps differ from natural daylight in that they do not have a continuous spectrum. They emit a high amount of light at certain wavelengths and almost nothing at adjacent wavelengths."
Correct. Which is what often makes a room look strange, dull and unappealing when lit solely by CFL light.
"However, in terms of the proportion of light emitted within the blue and red wavelength ranges, there are compact fluorescent lamps that are able to reproduce daylight more precisely than incandescent bulbs."
Correct. But 'full-spectrum' daylight CFL is a more expensive specialist product, just like there are Solux halogen daylight lamps which have even higher light quality and colour rendering properties. But these special products have little to do with the standard, reasonably affordable, CFL that people can buy in their local supermarket and which we are discussing as replacements for standard incandescent bulbs.
Economy

"Q: III.12. Aren't compact fluorescent lamps much more expensive than incandescent bulbs?
"Compact fluorescent lamps are actually much cheaper than incandescent bulbs if you consider also lamp life time and costs related to electricity consumption while using the lamps."
The original sales argument repeated once again. Is this a CFL FAQ or a CFL ad?
"During the lifetime of one compact fluorescent lamp you will have used 6-10 incandescent lamps. And the compact fluorescent lamp will consume one fourth / one fifth of the electricity consumed by incandescents, another cost saver."
I thought the "one fifth" argument was not going to be used anymore since it was already established earlier in this document that no CFL saves that much?
"A six-year-life energy-saving bulb would save about €60 during its lifetime (80W incandescent versus 20W compact fluorescent lamp). This is based on an assumption of 3 continuous burning hours per day, for an energy cost of 0,15 €/kWh.
Double envelope and poorer quality CFLs of course save less since they don't give as much light in the beginning and lose more as they age. If one has to replace the CFL sooner due to light loss, that too cuts savings. Same if one gets a CFL that gives up sooner than promised, or is used in the wrong luminaire. One may also be charged extra by one's utility to compensate for poor power factor, and pay extra for the heat loss in cooler climates etc.

So, net savings are often markedly less than promised in these optimistic calculations, especially with a poor quality CFL (it is actually more economic to pay more for a brand CFL, if you don't mind fluorescent light).

If EU should ban every top quality product on the market because there is a poorer quality product that might save the consumer a few euros per year (if used correctly) there would be very few products left. I wonder what would happen if the same policy was applied to the auto industry? (That might actually save the planet but it would probably not be very practical or popular...)
Total Energy Use

"III.13. More materials and energy are needed to produce a compact fluorescent lamp than an incandescent bulb, and it also results in more waste at the end of life. Does this not outweigh the benefits of its energy efficiency?

"According to the technical study ordered by the Commission to prepare for the regulation on household lamps (http://www.eup4light.net/), the impact of energy savings during the use of a compact fluorescent lamp clearly outweigh the environmental impact of its production and its end-of-life. Therefore using them rather than incandescent bulbs reduces the overall energy use and the environmental impact of lighting."
A more exact reference would be desirable. I'm sure they were made by CFL enthusiasts on the premises that CFLs "give 5 x more light"/"save 80% energy". And that they only cover the assembly, not the mining of rare minerals, turning the oil into plastic, or manufacturing and shipping of all the different parts (e.g. like the ballasts which, even for the same brand and lamp type, are made by many different manufacturers from different parts of the world).
Mercury
"III.14. Is it true that because of high energy use at start-up, compact fluorescent lamps have to remain switched on for 45 minutes before they bring any energy saving at all?

"No. The energy use of compact fluorescent lamps in the first 2 to 3 seconds of their operation is slightly higher, but after that their power uptake is stabilised. In practice, they provide energy savings right from the moment they are switched on."
Probably correct, though savings, as we have seen, are not as big as claimed. And many standard CFLs need to be switched-on for at least 15 minutes or more in order to not shorten their life, which makes them unsuitable and uneconomical in places you only visit for a short while, e.g. bathroom, closet etc.
"III.15. Compact fluorescent lamps contain mercury, a hazardous material, incandescent bulbs do not. If more compact fluorescent lamps are used, does it not mean more mercury pollution in the EU?"
"Mercury is present in compact fluorescent lamps in such a small amount that during its lifetime a compact fluorescent lamp (CFL) will have saved more mercury emissions from electricity production in coal power plants (compared to the mercury emissions related to the incandescent bulbs’ electricity need) than is contained in the CFL itself."


The usual flawed PR-argument recycled once more (see Mercury).
"Moreover, CFLs should be recycled according to EU legislation already in place."
Should be does not mean that all will be.But 5 mg x millions of CFLs still adds up to tons of mercury in landfills if not recycled properly. The fact that dental amalgam and old thermometers contain more mercury does not in any way make CFL mercury less of an environmental hazard, only makes it seem as if EU has some vested interest in downplaying the significance of mercury in CFLs.
"Compact fluorescent lamps have been widely used in European homes in the past decade, they will not be introduced by this regulation."
But they will be more or less mandated by banning its most popular and affordable competitors. The whole idea of this ban is to boost CFL sales, whether consumers want them or not, isn't it?

That CFL sales have been permitted for a decade without adequate information and routines for recycling is not exactly a point in favour of the CFL lobby, but a scandal in itself, as who-knows-how-many CFLs have already ended up in landfills?!
"Most office and public buildings, and also most streets have been equipped for the last 50 years with fluorescent and high-intensity discharge lamps containing mercury (often much more than compact fluorescent lamps)."
Correct, but linear FL tubes in offices are used in ceiling luminaires and street HID lamps are placed far above pedestrian level, neither which can be knocked-over or thrown away with household garbage, so there is little health risk to citizens, and businesses & public agencies usually have well-established recycling routines for their burned-out lamps. So the fact that other types of mercury-containing lamps have been used safely in non-residential environments is not as reassuring as it's meant to sound, and has absolutely nothing to do with home lighting or CFLs (which is what is being discussed here).
"The Waste Electrical and Electronic Equipment Directive (2002/96/EC) provides for the collection and recycling of waste electrical and electronic equipments (WEEE), including lighting equipment such as CFLs. The Directive sets out collection requirements for all WEEE, specific treatment requirements and a recycling target for gas discharge lamps (including CFLs). According to the requirements, mercury needs to be removed from the collected lamps through treatment, and their recycling should meet an 80% minimum target. Once consumers learn that they have to take back their burned-out CFLs to collection points just as they do with batteries, the mercury content will be recycled and not released to the environment."
"Member States have to ensure that users of electrical and electronic equipment are given the necessary information about the requirement not to dispose lamps as unsorted municipal waste and to collect such waste separately, as well as about the return and collection system available to them. After the regulation is adopted, the Commission will remind the Member States of the need to reinforce the recycling of CFLs on their territory."
I'm sure some member states already have or will be able to put time, money and effort into informing their citizens and establishing good recycling routines, while other member states may have more pressing matters on their agenda and few funds to finance such operations with.

And even with successful information campaigns and easily accessible recycling facilities, states still can't guarantee that every individual will comply. The only way to ensure no more mercury in landfills is to not allow mercury-containing products on the market if there exists a mercury-free alternative. And we do have such alternatives: incandescent, halogen and LED.
"The Commission also proposed to recast the WEEE Directive on 3 December 2008, so that the collection target for all WEEE is increased and the recycling target for gas discharge lamps is set at the level of 85%. This proposal will now go to co-decision with the Council and the European Parliament."
Good target but target still doesn't mean 85% will be recycled (see Recycling).
"From a life-cycle perspective, the proposed regulation is in any case the most eco-efficient solution. Indeed, according to the technical study ordered by the Commission to prepare for the regulation on household lamps (http://www.eup4light.net/), even in the worst possible case that a CFL goes to the landfill, during its lifetime it will have saved more mercury emissions from electricity production in coal power plants (compared to the mercury emissions related to the incandescent bulbs’ electricity need) than is contained in the CFL itself, so the overall mercury pollution balance will be positive."
Again assuming that:

a) all energy for light bulbs comes from coal, which is not correct (Eurostat says 29% of EU electricity production 2006 come from coal) and type of energy source may vary greatly between countries and regions;

b) CFLs save 80% energy, which they don't (more like 50% for the best, and less for the rest);

c) that reducing up to 1.5% of the c. 3% of domestic energy that is used for lighting will reduce emissions from coal fired power plants better than mandating filtering systems for EU power plants that would deal directly with the coal powered part of the remaining 97%. See http://www.ceolas.net/#li19x

"III.21. Compact fluorescent lamps contain mercury, which is a highly toxic substance. Do compact fluorescent lamps represent a danger to health because of that?"
"Mercury is an important component of compact fluorescent lamps (CFLs) that plays a key role in their energy efficiency and also other parameters such as lifetime and warm-up times. There are up to 5 milligrams (0,005 grams) of mercury contained in a CFL (compared to 0,5 g in dental amalgam filling or several grams in older thermometers). The 5 mg limit is set in the Restriction on Hazardous Substances Directive (2002/95/EC)."

"The mercury content cannot escape from CFLs, except in the event of accidental breakage of the lighting tubes. In that case less than 5 milligrams of mercury could be released."

Correct. And this is obviously too much, or safety guidelines would be unnecessary:
"The draft Ecodesign regulation requires manufacturers to explain on their websites how consumers should clean debris in case the CFL's tubes accidentally break, and to include on the packaging of each lamp the link to online explanations. Such an explanation is already available on the website of the European Lamp Companies Federation."
Good. Though one wonders how many were broken before these recommendations came up. And why the Commission hasn't issued its own guidelines.
"Buying commonly available CFLs with an outer non-breakable lamp envelope is another way to address the issue of mercury leakage in case of accidental lamp breakage, but the envelope slightly lowers (about 10%) their efficacy."
This doesn't eliminate the risk but lowers it (and makes the light less glaring and unattractive).
"Consumers who would particularly worry about mercury can choose alternative technologies such as improved halogen lamps."
See previous comments about the limited availability of halogen, and non-availability of frosted halogen.
About the incandescent ban

"III.2. By banning incandescent bulbs, are you forcing the use of compact fluorescent lamps? Are they not bad alternatives to incandescent bulbs?


"The best compact fluorescent lamps today can offer lighting functionalities approaching and in some respect surpassing that of incandescent bulbs (e.g. higher variety of colour temperatures)."
There are incandescent lamps too that come in 'peach', 'cream', 'daylight' etc. so this is not unique to CFLs. This sonds more like a desperate attempt at finding something good to say about them.

And this 'colour variety' diversion evades the questions, to which the answers are: yes - EU is forcing the use of CFLs, and yes - they are bad alternatives to incandescent bulbs, for all the reasons listed above and below and now confirmed by this very EU FAQ.
"In order to guarantee a minimum quality for compact fluorescent lamps on the market, the regulation also establishes requirements on product functionality (lifetime, warmup times, colour rendering etc.)."
This still won't make them start immediately or have perfect colour rendering like incandescent and halogen lamps since this is not possible with flourescent light technology.

Nor will retailers be prohibited from importing and selling poor quality CFLs. EU will just give a 'quality stamp' to those CFLs that are reasonably decent, meaning very little the regulations is like EnergyStar, which is based merely on manufacturer claims or tested on bulbs chosen by the manufacturer.
"The ENERGY STAR labeling program for residential lighting products merely requires data submission and certification by the product manufacturers. Product samples tested are “self-picked” by the manufacturer. No follow-up testing on actual products purchased from retail is required by ENERGY STAR. In addition, no centralized data review or challenge process exists within the lighting industry relative to the performance of residential ENERGY STAR lighting products."
U.S. DoE Eergy Star Lighting Verification Program
"Requirements for adequate information provision on the product functionalities will also ensure that consumers can make informed choices. See the other questions in section III for the details."
Similar but not the same. The main similarity is the frosted outer bulb on CFLs that have a double envelope. But fluorescent light doesn't radiate and glow like incandescent light does, as it's a 'dead' chemical light.
"but different light from clear (transparent) lamps which are bright point light sources. In order for such lamps to continue to exist, the regulation allows transparent improved (class C according to the lamp energy label) halogen bulbs on the market."
Correct. They may do to replace some clear bulbs, but are more glaring and may not be a suitable as replacement for frosted bulbs.
"Improved halogen bulbs provide exactly the same type and quality of light as incandescent bulbs or conventional halogens, they come in the same shapes and appearance, and fit into all existing luminaires. They start and provide their full light output as soon as they are switched on, and they are insensitive to frequent switching. These lamps can be useful also for consumers who are looking for alternatives to compact fluorescent lamps for other reasons (sensitivity to light or aesthetic considerations such as need for small lamps in decorative luminaires). Improved halogen bulbs for luminaires using incandescent bulbs are already available on the market, however their use is not yet widespread. Large manufacturers have them in their product portfolio (look for lamps such as 'HaloLux Classic ES', 'EcoClassic30' or 'MasterClassic EcoBoost')."
Correct. But the clear ones will only be permitted for a few more years. And the frosted Halogen Energy Savers will be forced off the market now in September - exactly one year after their market introduction! If this incandescent ban is not revoked, frosted retrofit Halogen Energy Savers must still be permitted indefinitely, or until an even better alternative has been created.

Frosted bulbs don't give less light than clear bulbs so there is no reason whatsoever to ban frosted other than to force people to buy CFLs against their will. Forcing consumers to buy a mercury-containing product they don't want - because it is an inferior quality product - is clearly a gross violation of personal freedom!
"I.8. People are likely to stock up incandescent bulbs when they hear about the regulation. Does this not weaken the impact of the measure?

"Communication to consumers about available equivalent alternatives to incandescent bulbs (such as improved halogen bulbs) could help prevent much of the stocking of bulbs. Consumers will realise in the end that the alternatives provide substantial savings and have equivalent light quality to incandescents. They might decide not to use their old energy-wasting bulbs, or to install them only in rarely used places such as cellars. Moreover, the estimate of 15 Mt CO2 savings was calculated for the year 2020, by then any delaying effect of "hamstering" will have disappeared."
That's 11 years away! By that time we need to have done some something about the real problems instead of hunting droplets in the energy ocean... like that less than 1% used for home lighting in Europe.
"I.9. Is it not disproportionate to ban incandescent bulbs from the market? Would it not be better to make use of other measures to achieve the switch (such as voluntary restrictions as in the UK, information to the public or taxation)?"

"The draft regulation introducing minimum efficiency requirements (rather than a voluntary approach) is in line with the principle of proportionality. There is clearly a market failure in moving to the alternatives providing the least life cycle cost to the consumers. Since 1998, household lamps have to indicate their energy efficiency on the packaging, thanks to implementing measure 98/11/EC of the Energy Labelling Directive (92/75/EEC)."
Which resulted in the CFL Quality Charter, right? The "Quality Charter" that requires only 660 (initial) lumen from a CFL to replace a 700 lumen standard 60W incandescent lamp, and permit labels that recommend an erroneous 1:5 switch (adressed earlier in III.3)? This is what the European Commission has said about it:
"The CFL Quality Charter is a voluntary scheme. It is opened to lamp manufacturers, CFLs importers and retailers willing to comply with the Charter rules and market in the European Union CFLs that meet the Charter requirements." [emphasis added]

Residential Lighting Consumption and Saving Potential in the Enlarged EU
Yet even such EU-sanctioned exaggerations from manufacturers, utilities and governmental agencies alike, obviously hasn't impressed consumers enough to replace all their top quality incandescent lamps with inferior quality CFL. Perhaps because they would rather save on something else than ruining their home atmosphere by compromising on something as essential as light quality?
"In spite of the clear indications provided on the packaging and campaigns in many Member States, consumers have failed to direct their choices to the more efficient lamps offering equivalent service, and have been largely sticking to incandescent bulbs. This is due to the fact that the purchase price difference between incandescent bulbs and more efficient alternatives constitutes a psychological barrier, even if the higher initial investment pays off within a year and brings substantial (but much less visible) savings over the life cycle. Another deterring factor has been the sometimes poor quality of the so-called economic lamps placed on the market without being subject to quality requirements. This market failure can only be tackled with mandatory requirements on the efficiency level of all household lamps placed on the market in the EU."


What? Manufacturers fail to produce a decent enough alternative and it is considered a "market failing" that people don't like the inferior product and refuse to replace all of their lamps, despite such an unprecedented global PR-campaign from governmental agencies, utilities and environmental organizations, including free giveaways, subsidies, events, commercials, articles, brochures - and most people nowadays really wanting to be green - so this has to be tackled with "mandatory requirements"? Doesn't that go against the very idea of the free market and consumer choice?
"This also serves the interests of the internal market, as voluntary restrictions or taxes introduced in certain Member States or by some retailer groups in Europe would create barriers to the free movement of goods. They would have different efficiency limits and timing of the restrictions. In addition, for taxation to be an effective deterrant, it should multiply by 10 the price of incandescent bulbs."
If the EU can legislate about a universal bulb ban, they can just as easily mandate a lower VAT for A-rated energy products and higher for E-rated products. Even a small price increase may inspire those who don't mind compromising on quality to buy alternative products. Especially when LEDs get affordable enough.
"Still the main point is that efficient lighting as provided for in the draft regulation is a way to save energy, to limit CO2 emissions and to help consumers save money without loss of functionality."


As we have seen above, the CFL doesn't save as much as claimed of either and functionality is lost for all those who for various reasons need top quality incandescent light and cannot tolerate CFL light (see Health & Wellbeing).

As this is not in accordance with the draft regulation and the decision seems to have been taken on the false premises that CFLs save "up to" 80% energy and lighting constituting 20% of home energy use when it is only around 3%, this should be enough grounds to revoke the ban and just keep educating people on energy saving measures while subsidising measures that can make a real difference, which is switching to alternative fuels/methods for space heating & cooling, electricity production and transport.

4 comments:

  1. Thank you for such a brilliant expose of yet another "Own Goal" by the European Union CFL legislation brigade!

    They are now in the process of attempting to ban incandescent reflector lamps including highly efficient and long life infra red coated MR16 low volt! I am yet again challenging their nonsense posted on eup4light.net! Get on their register, read the documents and submit comments. There are very few people doing this , we need a bigger mass of people prepared to challenge the dogmatic rubbish they keep writing!

    Kevan Shaw
    Director of Sustainability of PLDA

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  2. Quit spamming please. I was actually kind enough to leave your first link for several months, but since you started spamming with more links I deleted all your comments and will continue doing so since I don't appreciate spamming.

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