Tuesday, 22 December 2009

New EU Ecodesign Directive

Update 2012: An updated version of this post can be found at the new site:

Finally a look at the crucial parts of the Euorpean Union's recently amended (Oct 2009) Ecodesign Directive:

5. Implementing measures shall meet all the following criteria:

(a) there shall be no significant negative impact on the functionality of the product, from the perspective of the user;
With CFLs, the user gets a poorer quality light with mediocre colour rendering, sensitivity to heat, cold, moisture, frequent switching, dimmability problems, recycling difficulties etc. With WLEDs, a very dim light with strange light colour and suboptimal colour rendering and very high purchase price. With clear class C Halogen Energy Savers, glare. With clear class B Halogen glare, higher EMFs, and very high purchase price. Thus, this condition is not fulfilled.  
(b) health, safety and the environment shall not be adversely affected;
CFLs can not be considered safe for health or environment as long as they are breakable and contain mercury vapour. There are also many patient groups, an estimated 250 000 light sensitive people in EU, which SCENIHR thinks will be adversely affected, and anecdotal evidence for even more patient groups reporting subjective discomfort or ill-being in FL/CLF light. Thus, this condition is not fulfilled.
(c) there shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle cost of the product;

LEDs, class B Halogen lamps and top quality & dimmable CFLs are still prohibitively expensive to buy, even if they allegedly last longer. Thus, this condition is not fulfilled.
(d) there shall be no significant negative impact on industry’s competitiveness;

(e) in principle, the setting of an ecodesign requirement shall not have the consequence of imposing proprietary technology on manufacturers; and

(f) no excessive administrative burden shall be imposed on manufacturers.
I'll leave that part for manufacturers to comment, in the remote chance that they find anything to complain about.

As A, B and C are clearly not fulfilled, the incandescent phase-out is illegal and should be revoked - preferably before manufacturers have time to dismantle their local bulb factories.

Member states could still follow Peter Thornes' advice and agree to put an extra tax on the poorest performing bulbs so that they cost at least as much as their halogen replacements. That way people would probably buy a longer lasting energy saver, especially if frosted halogen bulbs were made available again. When LEDs become good enough and affordable enough, many will buy those instead. No need for the Commission to meddle.

Except to ban naked tube CFLs for private use, as they are a potential hazard to health and environment both. And xenon HID lights for cars, for safety reasons. And ineffective and low quality mercury vapour street lights & halophosphate FL tubes, for which there are much better replacement both quality- and quantity-wise.

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