The EU Lightbulb Ban

Revised version April 2015

Friday 24 April 15

This presentation will show how the EU ban on incandescent lamps is invalid by the Ecodesign Directive’s own criteria, as it fails to fulfill any of the requirements on functionality, energy savings, economy, health, and the environment.

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Contents Page

Lamp Technologies 4

Light Quality 6

Light Colour 13

Function 16

Energy 19

Economy 29

Environment 35

Health 44

EC Documents 60

Effects of Bulb Ban 67

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Lamp Technologies

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Luminescent LightLuminescent LightGas Discharge

(FL tube, CFL, HID)Solid State Lighting

(LED)

Incandescent LightIncandescent LightIncandescent Halogen

Electric Light Categories

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Light Quality

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Incandescent Light Natural, radiating light

Produced by heating a filament

Luminescent LightSynthetic light

Produced by complex chemical and technical processes

cbv.ns.ca

“incandescent light is produced by heating a solid object - the filament - until it radiates light. In a sense, this is the way light is produced by the sun.” - OSRAM

LED

Diagram: OSRAM

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Incandescent light and sunlight are “the two ‘golden standards’ of lighting” - Global Lighting Association

Incandescent LightAlways top quality, just like sunlight

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Incandescent LightNaturally full-spectrum

Luminescent LightNot full-spectrum

Complete spectrum with all colours visible Gaps with many wavelengths missing

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Full-Spectrum Light Perfect colour accuracy

Colour Rendering Index 100 = lossless

Non-Full-Spectrum Light Poorer colour accuracy

CRI only 80-85 = lossy

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Incandescent light is warm, clear and radiant

Photo: K2 Design (Houzz.com)

Makes all colours in a room look rich and vibrant, with optimal contrast

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Synthetic light is more grey and flat

Often too harsh and bright initially, then increasingly dull and dim as it ages

Kleppinger Design Group (Houzz.com)

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Light Colour

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Incandescent Light Colour A glowing tungsten filament radiates a

natural warm white light.

Luminescent Light ColoursA phosphor blend creates the light colour

and light spectrum.

energyblogs.com

The light colour is dynamic and turns slightly whiter at high wattage or low voltage.

The light color is fixed, ranging from warm-white to cool-white depending on the phosphor mix.

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Soft, warm, and naturally flattering

Incandescent LightMakes human skin look glowing and healthy

CFL & LED LightMakes human skin look pale and dead

Photo: Wikimedia

Soft, warm, and naturally flattering Any imperfections get harshly highlighted

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Function

“there shall be no significant negative impact on the functionality of the product, from the perspective of the user” - The Ecodesign Directive

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CFL & LEDOnly some are dimmable

Incandescent & HalogenAll are naturally dimmable

Dimming incandescent light makes it warmer and more candle-like, which is perceived as natural.

An incandescent lamp dimmed 30% will last 4 times longer.

Photos: Kevan Shaw

Dimming synthetic light makes it colder, which is the opposite of what looks and feels natural.

Dimming saves nothing, only raises price and may cause flicker or noise. Using a non-dimmable lamp with a dimmer switch will instantly fry the circuits.

Dimming

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Incandescent Bulb• Full light flow instantly• Colour rendition 100%• Temperature tolerant• Minimal flicker• Naturally dimmable • Compatible with all dimmers, timers etc• Sensitive to vibrations and power spikes• Gets fairly hot

Halogen Lamp • Full light flow instantly• Colour rendition 100%• Temperature tolerant• Minimal flicker• Naturally dimmable• Compatible with all dimmers, timers etc• Sensitive to vibrations and power spikes• Gets very hot

CFL• Takes time to reach full output...• Colour rendition 80-85% • Sensitive to heat & cold• High frequency flicker (24-100 kHz)• Very few dimmable (extra expensive)• Only work with some dimmers • Sensitive to rapid switching on-off• Creates more electrosmog

LED• Full light flow instantly• Colour rendition 75-85%• Sensitive to heat & power spikes• May flicker• Only some are dimmable • Only work with some dimmers • Creates more electrosmog• Cold to touch

Technical Issues Overview

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Energy

“The product shall present significant potential for improvement in terms of its environmental impact without entailing excessive costs”

- The Ecodesign Directive

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ElectricityHome Energy

Light

Incandescent

Home Energy UseEU-27 total final energy consumption = 1168 Mtoe1

Home energy consumption ≈ 25%1 of EU total

Electricity ≈ 22%1 of home energy (the rest is mostly used for heating or cooling)

Lighting ≈ 12.8%2 of home electricity ≈ 2.8% of home energy

Incandescent lamps ≈ 54%3 of home lighting ≈ 1.5% of home energy

1. EuroStat 20082. European Commission, Residential Lighting Consumption and Saving Potential in the Enlarged EU 3. VITO 2007 (p. 69, table 2-11)

Transport33%

Industry27%

Services13%

Households25%

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Heat/Light RatioThe small difference in light/heat output per watt (for the most efficient lamps of each type) constitutes the entire basis for the idea of ‘energy saving’ lamps.

0%10%20%30%40%50%60%70%80%90%

100%

Incandescent Halogen ES CFL LED

40%32%10%8%

60%68%

90%92%

HeatLight

CFLs and LEDs produce heat too, though less, and mostly internally.

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0%

20%

40%

60%

80%

100%

Incandescent CFL

‘Wasted’ Heat Useful Indoor HeatLight

Heat Replacement Effect• Indoors during the heating season, however, lamp heat is not wasted, but adds to room heat.

1. Canadian Centre for Householding Technology, Benchmarking of energy savings associated with energy efficient lighting in houses2. UK Market Transformation Programme, BNXS05: The Heat Replacement Effect 2007

“The [67%] reductions in the lighting energy use [by CFLs during the heating season] are almost offset by increase in the space heating requirements. The results showed that 83% to 100% of lighting energy consumption could contribute to the internal gains.”1

• Outdoors and during the cooling season, CFLs save a larger portion of their original 67%.

• On average, over the whole year, 60% of the heat from home lamps can turn into useful heat with CFLs saving only 20%.2

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Incandescent Lamps Optimal Power Factor (1.0)

CFL & LED LampsLower Power Factor (0.4 to 0.9)

Circuits with only heating elements have optimal power factor (PF), producing a smooth sine curve.

Circuits with inductive or capacitive elements have lower power factor, producing a highly distorted waveform.

Power Quality (Lighting Research Center)

Poor PF can cause RF/EMF pollution, waste energy, harm the electrical distribution system, and reduce the life of lighting systems or other electrical equipment!

Power Factor

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EU Power Factor Requirements For the consumer market, the minimum PF requirements are surprisingly slack:

CFLs CFLs LEDsLEDs

2-4 W PF min 0.4

Under 25 W PF min 0.5 5-24 W PF min 0.5

25 W or over PF min 0.9 25+ W PF min 0.9

New EU RequirementsPower Factor (Sylvania)

Producing CFLs and LEDs with higher Power Factor is possible but more costly, so that option is often reserved for the professional lamp market due to utility penalties if too low.

“Utilities may impose penalties on customers who do not have good power factors on their overall buildings.” - Sylvania

Dimmable LEDs tend to have poorer PF

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0

5

10

15

20

25

30

15W CFL 12W LED

WattsVolt-amperesBallasts (W)

Real Energy Used As most lamps used at home are under 25 watts, this means the average ‘energy saver’ uses almost twice the energy (e.g. 25VA instead of 15W!) = lamp energy ratings are incorrect!

CFL Real Power Used Power Factor (Sylvania)

“While the consumer saves watts with any of the compact fluorescent alternatives, the utility must generate nearly the same amount of VA for the magnetic adapter unit as for the incandescent lamp.”

- Sylvania

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Real Energy Use Tested

Benchmarking of energy savings associated with energy efficient lighting in houses

Measurements (highlighted here) made by the Canadian Centre for Housing Technology confirms the poor power factor (PF) and higher energy use in volt-amperes (VA) for typical CFLs vs. incandescent lamps.

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Jevon’s Paradox When people believe a product saves energy, they will only buy more products or leave them on for longer.

“Contemporary economists talk about what they call ‘the rebound effect’. This occurs when the savings that come from using more energy-efficient machines are offset to some extent by the increased use of machines.”

The Energy Efficiency ParadoxViva Las Vegas: LEDs and the energy efficiency paradox

“The guy burning one light bulb in his little room (and maybe using the excess heat of his bulb as heating in winter) damages the environment a whole lot less than the guy on the other side of the street who decorates his mansion and garden like a casino with LEDs.

There is a lot of room to lower energy consumption without switching to new technology. Something is awfully wrong with our approach to energy conservation.”

The simplest way to save energy is to simply turn lights off when not in use, or to use dimmers with one’s incandescent lamps. Information campaigns worked wonders for energy conservation in the 1970s, so why not try it now when people are even more motivated and aware?

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Summary Energy Savings So, about 20% actual savings (with Heat Replacement Effect included)

minus roughly half (with poor Power Factor included) ≈ 10% of the 1.5% of home energy used by incandescent lamps

≈ 0.15% of an average EU household’s total energy consumption...

0

25,0

50,0

75,0

100,0

Home energy Savings

...or less if you use more lamps, thinking you save so much

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Economy

“There shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle cost of the product.”

- The Ecodesign Directive

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Incandescent LifeOriginally 2 500+ hours

After 1924 designed to break after 1 000 hrs

Long Life: up to 10 000 hrs

(U.S. Long Life: 20 000 hrs)

Halogen LifeHalogen bulbs for home use are designed to last about 2 000 hours

With a PowerDisc an incandescent or halogen lamp can last 100 000 hours!

Life Span

Long Life: up to 10 000 hours

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LED LifeRated life: 15 000 to 50 000 hours, but:

• Only the diodes, not the whole lamp.

• The electronics are very sensitive to overheating, e.g. in enclosed fixtures.

• Light produced by current through a semiconductor, which can malfunction due to poor materials or power spikes.

CFL LifeRated life: 5 000 to 15 000 hours, but:

• Easily get overheated in small / enclosed fixtures.

• Base up burning position can reduce life down to 25% of rated life.

• Designed to be left on for 3 hours. On for 1 hour = down to 80% of rated life!On for only 5 minutes =15% of rated life!

Chen W, Davis R, Ji Y., An Investigation of the Effect of Operating Cycles on the Life of CFLs” (1998) Video where typical on times in various rooms are timed

LED Life Expectancy Depends on Fixture Type and Usage ScenarioThe great LED lightbulb rip-off: One in four expensive 'long-life' bulbs doesn't last anything like as long as the makers claimDo LEDs Have a Dark Side?

LEDs and CFLs which do not expire prematurely will gradually get more and more dim, making their useful life much shorter than their nominal life.

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Approx. Price for Lamps Lasting10 000 Hours

€2

€6-18

€10-30

€2.5

€0.5 10 GLS≈ €5

1 LongLife≈€2.5

5 halogen ≈ €10

4 CFLs?≈ €24-72

1 LED?≈ €10-30

?

?

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• Due to the poor Power Factor of most household lamps under 25W, the more people use CFLs and LEDs, the more utilities have to increase electricity prices to compensate themselves for the losses!

Additional Costs

• Many CFLs and LEDs are subsidised by tax money.

• When using CFLs, you need to have a mercury spill kit (38 to 370 €) at hand in case of accidents.

• After use, CFLs and LEDs have to be taken to a recycling plant for toxic waste which also adds extra costs.

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Summary ‘Money Savings’ As CFLs and LEDs often:

• don’t give as much light as claimed

• use more energy than claimed

• don’t last as long as claimed

the markedly higher price does not save the consumer any money!

The only ones making money from the ban are the Big Lighting corporations!

LEDs are much more profitable than incandescent lamps, and sales are expected to grow by 30% annually - now that the main competition, the incandescent bulb, has been banned!

Lighting in Europe alone is a ~17 billion € business!

€€

Instead of penalizing manufacturers for consumer fraud, the Commission is helping them do it!

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Environment

“Health, safety and the environment shall not be adversely affected”

- The Ecodesign Directive

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Incandescent Bulb

Made of:

• Glass (bulb)• Tungsten (filament)• Molybdenium, copper, iron, nickel (support, wires)• Aluminium or brass (base)• Tin & antimon (solder)• 15% nitrogen, 85% argon (inert gas)

Halogen Lamp

Simple to manufacture

May contain:

• Quartz glass (tube or inner bulb)• Glass (outer bulb)• Tungsten (gfilament)• Molybdenium, copper, iron, nickel (support, wires)• Aluminium, brass or ceramics (base)• Bromine or iodine (halogen gas)

General Electric, Osram-Sylvania material safety data sheets, How it’s made (video)

Lamp Materials

Very simple to manufacture

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General Electric, Osram-Sylvania, Home Depot, LiteTronics.com, MineralsCoalitionEducation.com

LEDComplex and expensive to manufacture

May contain:• Glass• PMMA, PBT el PET (brominated polymer)• Aluminum (heat sink and housing)• Nickel plated brass (base)• Bauxit (glass and adapter)• Lead (glass and adapter)• Copper (adapter and wiring)• Nickel (adapter)• Zink (adapter; semiconductor)• Tin (adapter; solder)• Manganese, barium/aluminum oxide (phosphor) • Rare earth metals (phosphor)  + Arsenic, boron, gallium, indium, selenium or phosphate (chip, depending on colour)

CFLComplex and risky to manufacture

May contain:• Glass • Tungsten (anode & cathode)• Aluminum, copper, nickel, tin or zink • Nickel-plated brass (base)• PBT or PET (bromnated polymer)• Krypton-85 (gas)• Mercury (vapour or amalgam)• Lead oxide• Lead (solder), in EU after 2006: tin • Manganese, barium or aluminum oxide (phosphor)• Rare earth metals (phosphor)

EE Times

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CFL Mercury CFLs and LEDs are not easily disposed of as they classed as toxic waste. Hazardous to humans, animals and the environment if CFLs end up in land fills, for dumpsters in poor countries, and for recycling staff.

Waste dump with broken lamps (from documentary Bulb Fiction)

"...recycling doesn’t seem to be very profitable. As a consequence, many people don’t know what to do with their used lamps, moreover they don’t even know that CFLi’s are containing mercury."

Final Report. Lot 19: Domestic lighting. Study for European Commission, 2009,p. 105. Recycling of CFLs Mercury in Fluorescent Lighting

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One kg can poison 15 lakes.

CFL MercuryOne teaspoon of mercury is enough to poison a medium size lake!

“In 2007, 353 million CFLs were sold in the EU27. Their content of mercury averaged 4 mg. We assume that 20% of the lamps were recycled, what still leads to the amount of 1,130 kg.”1

1. Mercury in Fluorescent Lighting

One kg can poison 15 lakes. That makes 16 950 lakes! And this was before the incandescent ban!

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The Mercury ‘Justification’So, how does the Commission justify granting CFLs exemption from the RoHS directive mandating phaseout of mercury in household products?

It appears by believing and forwarding the vested interest’s propaganda about mercury:

This clever PR argument was created in 1991 from a faulty Danish LCA study using the Danish percentage of coal in electricity generation - which at that time was the highest in Europe, 95%!2 EU overall coal share was significantly smaller then, and is even smaller today. Many countries use no coal at all. So this argument is totally invalid. VITO also made (deliberate?) miscalculations in the preparatory study order to make CFLs appear to release less Hg.3

In order to reduce mercury emissions, regulate coal & gold mining - and ban CFLs!

Not a randomly chosen consumer product that contains no mercury or toxic elements and uses only 0.15% of home energy.

“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 conventional incandescent bulbs’ electricity need) than is contained in the CFL itself.” 1

1. Frequently asked questions about the regulation on ecodesign requirements for non-directional household lamps 2. Gydesen, A. & Maimann, D., Life Cycle Analyses of Integral Compact Fluorescent Lamps versus Incandescent Lamps (1991)3. Historical survey of the introduction of the ban on incandescent lighting in the European Union, chapter 6

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Rare Earth PhosphorsLEDs and CFLs contain rare earth phosphors, the mining of which ruins the environment in Asia.

“Miners scrape off the topsoil and shovel golden-flecked clay into dirt pits, using acids to extract the rare earths. The acids ultimately wash into streams and rivers, destroying rice paddies and fish farms and tainting water supplies.” - New York Times

Photo: Liam Young/Unknown Fields

The dystopian lake filled by the world’s tech lust (BBC) Earth-Friendly Elements, Mined Destructively (New York Times)

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1. Potential Environmental Impacts from the Metals in Incandescent, CFL, and LED Bulbs2. LED products billed as eco-friendly contain toxic metals, study finds

“The CFLs and LEDs have higher resource depletion and toxicity potentials than the incandescent bulb due primarily to their high aluminum, copper, gold, lead, silver, and zinc.

Comparing the bulbs on an equivalent quantity basis with respect to the expected lifetimes of the bulbs, the CFLs and LEDs have 3–26 and 2–3 times higher potential impacts than the incandescent bulb, respectively.”

Other MetalsCFLs and LEDs have higher environmental impact than incandescent lamps.1

Coloured LED holiday lights contain high levels of toxic elements, such as arsenic and lead.2

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Summary EnvironmentLife Cycle Analyses are often made by lamp manufacturers themselves, based on very optimistic projections on light output per watt and nominal life rate for their best lamps under optimal conditions, and usually excluding:

Taking these things into account will generate very different results.

High lumen CFLs and LEDs may have some use in the commercial and public sectors, especially outdoors, but are are not a green alternative at home.

• energy and environmental impact of mining for the raw materials (production phase)• energy and environmental impact of manufacturing the different parts (production phase)• transport of the various parts (often from different countries) to the factory for assembly • transport from the factory in Asia on dirty oil tankers (distribution phase)• the higher real energy use due to poor Power Factor (operating phase)• the c. 60% Heat Replacement Effect (operating phase)• the light loss as the lamp ages (operating phase)• premature death due to poor quality, overheating, wrong use etc. (operating phase)• collection and transport after use (scrapping phase)• recycling of the toxic metals (scrapping phase)

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Health

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S

Mercury in ProductionHazardous for miners, for the environment, and for workers in manual CFL factories.

Sweat shop in India (screenshot from Austrian documentary Bulb Fiction)

“Large numbers of Chinese workers have been poisoned by mercury, which forms part of the compact fluorescent lightbulbs. A surge in foreign demand, set off by a European Union directive making these bulbs compulsory within three years, has also led to the reopening of mercury mines that have ruined the environment.”

‘Green’ lightbulbs poison workers (The Times)

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Using CFLs requires having a mercury spill kit at hand in case of accident. How many people know this? How many can afford €130-300 for a one-time kit?

Mercury at HomeMercury vaporises at room temperature (!) and is easily absorbed by the body, where it can cause severe damage to the central nervous system. Extra big risk for children & pregnant women!

“Mercury causes nervous system defects in children and impedes fetal development.”Toxipedia

How many have had their homes contaminated and children exposed since 2009?

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U.S. EPA Cleanup Guide1. Before cleanupa. Have people and pets leave the room.b. Air out the room for 5-10 minutes by opening a window or door to the outdoor environment.c. Shut off the central forced air heating/air-conditioning system, if you have one.d. Collect materials needed to clean up broken bulb:

• stiff paper or cardboard• sticky tape• damp paper towels or disposable wet wipes (for hard surfaces)• a glass jar with a metal lid

2. During cleanupa. DO NOT VACUUM. Vacuuming is not recommended unless broken glass remains after all other cleanup steps have been taken. Vacuuming could spread mercury-containing powder or mercury vapor.b. Be thorough in collecting broken glass and visible powder.c. Place cleanup materials in a sealable container.

3. After cleanupa. Promptly place all bulb debris and cleanup materials outdoors in a trash container or protected area until materials can be disposed of. Avoid leaving any bulb fragments or cleanup materials indoors.b. Next, check with your local government about disposal requirements in your area, because some localities require fluorescent bulbs (broken or unbroken) be taken to a local recycling center. If there is no such requirement in your area, you can dispose of the materials with your household trash.c. Continue to air out the room where the bulb was broken and leave the heating/air conditioning system shut off for several hours.

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EUThe European Commission has not issued any warnings or mercury cleanup guidelines!

The ‘new’ EU requirements for labeling mercury content came 3.5 years after the first stage of the phaseout!

And they are still pitifully small, cryptic and easy to miss!

How many even know that Hg means mercury?

How many know what the number means?

How many know what do do in case of an accident?

How many have an expensive spill kit at home?

How many unsuspecting children and pregnant women have been exposed to mercury since 2009?

CFLs should be marked with a skull-&-crossbones warning, as suggested by environmental expert Minna Gillberg 2009.

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Phosphor Accidental cuts on the glass of a broken CFL means not only risk of mercury poisoning but can get very nasty as the phosphor powder stops the blood from coagulating.1

1. The Fluorescent Lighting System Images from: Energy Saver Globe

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FlickerLamps powered by AC electricity flicker at twice the line voltage rate (50 or 60 Hz).

• Flicker has been shown to have negative effects on health and performance• Light sensitive epilepsy (one in 4 000 people) can be induced by flicker

• Ménières may be aggravated by flicker

• Migraine can be triggered by visible flicker

Küller, R & Laike, T, The impact of flicker from fluorescent lighting on well-being, performance and physiological arousal (1998)Health Effects of Artificial Light (SCENIHR, 2008/2012) (Wikipedia summary)Proper driver design eliminates LED light strobe flicker

Many LED lamps flicker, some visible like a strobe light

CFLs and fluorescent tubes with conventional magnetic drivers sometimes flicker perceptibly, whereas CFLs and fluorescent tubes with with electronic high frequency drivers turn on and off 10 000 to 40 000 times per second.

Incandescent and halogen lamps flicker less and more softly, as the tungsten filament keeps glowing between AC-pulses.

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GlareThe extra concentrated light intensity of clear or directional LEDs can cause harmful point source glare.

1. ANSES, French Agency for Food, Environmental and Occupational Health & Safety (2010) - Original report (fr) Summary (eng)

“These new lighting systems can produce ‘intensities of light’ up to 1000 times higher than traditional lighting systems, thus creating a risk of glare.

The strongly directed light they produce, as well as the quality of the light emitted, can also cause visual discomfort.”

- ANSES

Clear halogen lamps can also be quite glaring, so the random ban of frosted halogen lamps 2009 removed the only high-quality glare-free incandescent alternative!

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CFL tubes emit ultraviolet radiation through cracks in the phosphor layer1

which can cause skin cancer and eye damage.

CFL UV Radiation Hazard

“Sustained exposure to ultraviolet light wavelengths from CFLs increases the risk of two seriously debilitating eye conditions, macular degeneration and cataracts”2, 3

1. The effects of UV Emission from Compact Fluorescent Light Exposure on Human Dermal Fibroblasts and Keratinocytes In Vitro2. Emissions from compact fluorescent lights (Public Health England, 2008)3. Eye Disease Resulting From Increased Use of Fluorescent Lighting as a Climate Change Mitigation Strategy (2011)

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LED Blue Light HazardLED health risks comes from the spikes of short (blue) wavelenghts.

The accumulated effect of low exposure can be as big a risk as short, intense exposure.

Warm white LED spectrum Cool white LED spectrum

ANSES, French Agency for Food, Environmental and Occupational Health & Safety (2010) - Original report (fr) Summary (eng)

“The blue light necessary to obtain white LEDs causes toxic stress to the retina.”

- ANSES

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Blue Light Retinal Damage

Further evidence of LED light damaging your eyes

“The present data clearly demonstrated irradiation of the white LED is above 400 nm and is not within the ultraviolet light region. However, the exposure of eye in LED illuminated environment was related to the development of photoreceptor loss.”

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Groups Especially at RiskGroups dependent on incandescent light for their health have now been deprived of safe alternatives and the Commission has not provided any useful alternatives.

ANSES, French Agency for Food, Environmental and Occupational Health & Safety (2010) - Original report (fr) Summary (eng)Health Effects of Artificial Light (SCENIHR, 2008/2012) (Wikipedia summary)

• Patients with UV sensitive skin conditions (photodermatoses, incl. Bloom & Rothmund-Thomson syndrome, xeroderma pigmentosum, actinic prurigo, chronic actinic dermatitis, urticaria solaris, polymorphic light eruption, photophobia)

• Patients with blue light sensitive eye conditions (AMRID, aphakia, pseudo-aphakia (whose eyes cannot, or can only partially, filter blue light)

• Patients with blue light sensitive skin conditions

• Children (whose eyes cannot yet filter blue light well)

“There are a number of patients (around 250,000 EU citizens; SCENIHR 2008) that are exceptionally sensitive to UV/blue light exposure. The risk for this group of patients includes all light sources with significant UV/blue light emissions.”

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Blue Light Bio-DisruptionBlue-white light inhibits melatonin even at very low light levels, and can cause problems with sleep, mood, and metabolism, leading to conditions like obesity, diabetes, or depression.

Red and infrared wavelengths are needed, especially in the evening, in order to stimulate regenerative processes in the body.

Incandescent light has a larger portion of red and is therefore the best light source at home at night.

Dimmed incandescent light is even more ideal, as it gets more red and less bright.

Stephen M. Pauley, M.D. - Lighting for the Human Circadian ClockToo little light in the day, and not enough darkness at night: How our sleep patterns are changing for the worse

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General Health & WellnessBesides being all-important for vision and mood, light is an essential bio-nutrient.

Quality matters!

Banning top quality incandescent & halogen light and mandating CFLs and LEDs is like banning fresh organic vegetables and allowing only junk food!

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EM Emissions & SafetyMost LEDs are made in China/Taiwan by a wider range of small and large companies than for traditional lamps, which also creates greater quality variations and more electrical safety and electromagnetic compatibility issues.

1. 4th EMC Market Surveillance Campaign 20112. More LED Issues3. Philips Recalls 99,000 LED Light Bulbs Due to Shock Risk4. Lighting Science issues recall of 554,000 LED bulbs because of fire hazard

“Dimmable LED lamps contain control electronics that often require specific measures to achieve acceptable properties to make electrical devices work together, known as electromagnetic compatibility (EMC). This is sometimes overlooked by the lamp manufacturers.”

In the electromagnetic compatibility (EMC) surveillance campaign on LED lamps 2011, 168 lamps were tested for electromagnetic emissions (harmonics and radio frequencies due to poor Power Factor from cheap drivers).

Only 61.5% passed the tests and almost 24% were either not CE marked or did not carry a compliant CE marking.1

Many batches of LEDs have also been recalled due to electrical safety issues. 2, 3, 4

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Summary Health RisksPotential health risks from:

• Mercury (CFLs)

• Phosphor (CFLs & LEDs)

• UV radiation (CFLs, unfiltered halogen lamps)

• Blue light hazard (LEDs, especially when the die is visible)

• Blue light hormone disruption (LED lamps & OLED screens)

• Flicker (some LEDs and CFLs with magnetic ballasts)

• Harmful glare (clear & directional LEDs, clear & directional halogen lamps)

• Electrical safety issues (some LEDs)

Even though SCENIHR, The European Commission and ELC have done their best to downplay them, these health risks cannot be ignored.

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EC Documents

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The Ecodesign DirectiveThe Ecodesign Directive (2009) includes the following criteria:

2. The criteria referred to in paragraph 1 are as follows:

(a) the product shall represent a significant volume of sales and trade, indicatively more than 200 000 units a year (...)

(b) the product shall, considering the quantities placed on the market and/or put into service, have a significant environmental impact within the Community (...)

(c) the product shall present significant potential for improvement in terms of its environmental impact without entailing excessive costs, taking into account in particular:

    (i) the absence of other relevant Community legislation or failure of market forces to address the issue properly;

    (ii) a wide disparity in the environmental performance of products available on the market with equivalent functionality.

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;

(b) health, safety and the environment shall not be adversely affected;

(c) there shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle cost of the product.

(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.

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The Biased VITO StudyDutch consultants VITO’s technical study, ordered by the Commission to prepare for the regulation on household lamps, appears to have been designed to produce a specific result, already determined in advance and therefore highly flawed on too many counts to list. Here are but a few examples:

• Lumping together all CFL models into one group (bare, covered, dimmable, outdoor, daylight, etc., despite their widely varying quality levels, efficacies, applications, energy ratings, and rated life) and using the optimistic nominal values of the most efficient CFL type to represent the whole group!

• Putting clear and frosted GLS in separate classes, despite the difference in output being virtually non-existent and all other things the same.

• Miscalculations of Hg emissions!

• Overly optimistic estimations of CFL recycling rates, 20% in all of EU, despite lack of recycling schemes.

• Not counting the mining process for the mercury and phosphors in CFLs (stating a ‘lack of info’).

• Making distribution impact estimates on the assumption that all lamps are produced in Europe, while fully aware (= mentioning!) that most CFLs are produced in Asia!

• Downplaying health effects and technical issues and giving incorrect information.

Friday 24 April 15

The Misleading Technical BriefingAs basis for the lightbulb ban, a grossly misleading summary was presented to the MEPs.

“Lighting may represent up to a fifth of a household's electricity consumption.”

The correct number according to the Commission is a mean of 12.8% (or 2.8.% of total household energy)

“There is a four to five-fold difference between the energy consumption of the least efficient and the most efficient lighting technologies available on the market.”

Only in theory. In reality, with Heat Replacement Effect and Power Factor, only a few watts, or about 10%.

“This means that upgrading the lamps could reduce a household's total electricity consumption by up to 10-15% (...)”

But lighting is only 12.8% of home electricity, and only 54% of those were incandescent in 2007! This makes 6.9% of home electricity. Saving 10% of that is 0.69%! (And synthetic light is always a downgrade.)

“In the context of the commitment of European leaders to reduce primary energy consumption by 20% compared to projections for 2020, the Spring European Council 2007 invited the Commission to ‘rapidly submit proposals to enable increased energy efficiency requirements (…) on incandescent lamps and other forms of lighting in private households by 2009’.”

Note how the initial “fifth” is made to seem like the 2020 goal by misrepresenting the numbers.

But home energy is only 25% of EU total energy consumption Home electricity is only 22% of a household’s total energy consumption = 5.5% of EU total energy Lighting is only 12.8% of home electricity = 2.8% of household energy = 0.7% of EU total energy

of which only was 54% incandescent before the ban = 0.38%, of which saving 10% = 0.03%!

Friday 24 April 15

The Halogen LieWhile the halogen phaseout scheme was given on the EU page for lighting professionals...

Friday 24 April 15

The Halogen Lie...EU private consumers were led to believe that halogen energy savers would still remain available indefinitely for those who want or need an incandescent alternative:

Friday 24 April 15

The Halogen Lie

• But B-class incandescent (halogen) bulbs do not exist! They were produced by Philips only for a brief period around the initiation of the ban and then removed from the market.

• C-class halogen energy savers will be banned from 2018 (original plan 2016).

So, these assurances were just lies and European consumers will have no quality lamps left to buy!

Friday 24 April 15

Effects of Bulb Ban

Friday 24 April 15

Consumer Confusion

Friday 24 April 15

Incandescent SimplicityWhen buying a new light bulb, wattage used to be all you needed to know.

Puzzling Lamp JungleNow you have to learn to decipher over a dozen new technical parameters.

Without professional help, chances of getting the right bulb for one’s lighting needs are slim.

All lamps were cheap, top quality and had perfect functionality, so purchase was easy.

Friday 24 April 15

Not Interchangeable

Same top light qualitySame top light quality Lower quality, different functionality Lower quality, different functionality

Same mediocre light qualitySame mediocre light quality

CFLs can only replace or be replaced by LEDs

Incandescent bulbs can not be replaced by CFLs or LEDs

Same top light qualitySame top light quality

Clear incandescent bulbs can only be replaced by clear halogen bulbs

Frosted incandescent bulbs can only be replaced by frosted halogen bulbs

Friday 24 April 15

• Highly Sensitive People

15-20% of the population are highly sensitive (HSP).

According to informal polls, a majority seem to prefer and feel best in incandescent light (or candle light) and strongly dislike fluorescent tubes, CFLs and LEDs.

• Seniors

Quantity: Lighting needs increase dramatically with age. Some may actually need a 150 watt halogen torchiere to light up the room instead of several dull CFLs.

Quality: Distinguishing colours gets harder with age. CFLs and LEDs are therefore unsuitable due to the suboptimal colour rendition.

Glare: Sensitivity to glare increases with age. Frosted incandescent and halogen lamps are the only non-glaring, good quality option.

Deprived Consumer Groups

Friday 24 April 15

• Art & Colour Professionals

Many professionals, e.g. artists, conservator-restorers, dental technicians, decorators, designers, fashion designers, florists, makeup artists, interior designers, lighting designers, photographers, cosmetic surgeons, etc., are often highly dependent on perfect colour rendition (= incandescent/halogen light).

Capriciously robbing all these groups of important tools needed in their respective professions can hardly be considered acceptable in a free market.

Deprived Professional Groups

Friday 24 April 15

As it is not, and never will be, technically possible to produce the same warm and radiating light by synthetic techniques, banning incandescent light is the same as banning beauty, comfort and the ability to create a cosy, relaxing, and attractive home environment. It also affects high-end shops, restaurants, hotels, galleries, museums, etc.

Banning Beauty

Friday 24 April 15

Conclusion1. As the Ecodesign Directive clearly states that implementing measures shall meet ALL the criteria, the incandescent ban and impending halogen ban 2018 is thereby invalid and must be revoked with no delay.

2. CFLs containing mercury vapour should be immediately banned from sale for the private consumer market, in accordance with the RoHS Directive and the Minamata Convention.

Those who have lobbied for and forced this toxic technology on an unsuspecting public, and also contributed to serious health- & environmental problems in Asia, should be held accountable.

Friday 24 April 15