Although the initial deadline for the first phase of the European Union (EU) EcoDesign Regulation has passed (September 1, 2013), there is still a lot of debate and contention around the initiative to replace various halogen lamps with LED lighting. Specifically, LightingEurope believes that no LED-based lamps will meet the Stage 6 requirements of European Commission (EC) Regulation 244/2009. In other cases, proponents of a faster transition to energy-saving solid-state lighting (SSL) believe that the EU should have mandated a faster transition — for instance, in directional products such as MR16 lamps.
EU Regulation 244/2009 sets minimum performance requirements (minimum lamp efficacy and lumen equivalency with incandescent lamps) for non-directional light sources, including LED lamps. Other EcoDesign Regulations such as EU 1194/2012 cover directional LED lamps, LED modules, and LED control gear, and still other EcoDesign Regulations cover efficiency in products well beyond the lighting space.
LightingEurope, the association representing lighting manufacturers and national lighting associations, has asked for a re-think on the timing of Stage 6 of 244/2009. That stage, among other things, will address non-directional, screw-based lamps and essentially phase out halogen lamps as an option. LightingEurope advocates that 2019 is a more realistic date for halogen bulbs to be replaced, rather than the current deadline of 2016. There are several reasons for this request: affordability, a desire for consumer choice, and quality issues.
Jürgen Sturm, secretary general of LightingEurope, is concerned that an accepted technology is taken away with no viable alternative offered. "It is not the technology, more the LED market maturity," he said. A mains voltage halogen bulb today costs around €1.00–€1.50 ($1.30–$2.00), whereas depending on the application and the country of purchase, a replacement LED can cost €15.00–€20.00 ($20.00–$27.00), he estimates. There has to be consumer choice, he argues, and 2016 is too soon for the market to be able to lower costs. Instead, he believes 2019 may be the right time for high-quality LEDs to be available to consumers at the right price point.
Peter Hunt, CEO of the UK's Lighting Industry Association (LIA), adds, "One of the reasons that LightingEurope is in favor of delaying the effective ban on halogen is the potential impact on jobs within the EU, in addition to the likelihood that quantities and quality, plus affordability, won't be available in 2016." He balances the panic of the 2016 deadline with the details of the EU bureaucracy, saying that it provides for a revision to ensure that the technology is on track to deliver the amount and quality of affordable lamps to replace those removed from the market.
Consultation and surveillance
The LIA understands that the Commission is likely to engage a consultant to make a market assessment, possibly in consultation with stakeholders. This is also likely, it says, to require confirmation by member states following a Regulatory Committee vote.
Another concern of LightingEurope is that the EcoDesign Regulation was introduced without industry consultation. The fear is that halogen bulbs will be phased out before the market is mature, leaving low-quality LEDs to be seen as the only option, based on prices. This will be detrimental to the maturing market, Sturm warns.
The same issue, he reasons, could damage market credibility. If the 2016 deadline does not allow producers to deliver quality products at an acceptable price, consumers may not have any option but to buy LED bulbs based on price when choosing a product from the store shelves. This could damage the consumers' image of what is "the most energy-efficient light source invented," says Sturm, "but the guiding principal must be consumer choice."
A related issue is that there is no provision for what Sturm calls "market surveillance." Each EU member state is to be responsible for policing the pricing and quality of LED replacements. What is affordable in Sweden may be unacceptable in Romania, for example, he points out. The lack of market surveillance in member states is a particular worry for LightingEurope.
Nick Farraway, international sales manager at Soraa, agrees that the EU has fallen short by making each member state responsible for implementing the Regulation. "Some countries are better than others; some will take reasonable steps to check retailers' shelves, but others muddle the issue," he argues. While large producers will protect their brands, there will be many products imported without quality controls and sold alongside the expensively produced ones.
"While some companies will follow the Regulation, there will be no checking or action if others do not," Farraway warns. This not only creates an unfairness in the market but could do harm as consumers, buying cheaper brands, are left with a poor impression of LED lighting. He argues that consumers may not see that replacing a halogen mains or low-voltage bulb that achieves an efficiency of 9–17 lm/W with an LED bulb of 50–60 lm/W is an energy-efficient option when the cost can be six times that of a halogen bulb. For hotels and commercial installations, the payback period should be 6–12 months, but for homes, where lights are used less, the payback may be extended to a period of 3–4 years, which is not such an obvious financial return for consumers.
For Farraway, there are other flaws in the EcoDesign Regulations. One is that the low specified CRI (color rendering index) may deter end users from LED lamps. Halogen lamps are popular with consumers because they render color well, he says, enhancing interiors. He is concerned that the EU is allowing quality to be diluted. He fears lessons have not been learned from the introduction of energy-efficient compact fluorescent bulbs. "Compact fluorescent is a good technology to save money, but is a poor light, and therefore unpopular," he says, referring to its green hue. He wants a much more stringent color metric for replacement bulbs. The EU wants 80 CRI, but Farraway wants 95 CRI or greater, although he concedes that the obstacle to this is a more difficult and more costly process technology.
Typical LED manufacturing lines today use gallium nitride (GaN) on sapphire substrates and, to a lesser extent, the newer GaN on silicon carbide. These can be seen as the "incumbent" LED materials, alleges Farraway, who advocates Soraa's GaN on GaN as an emerging technology that is "infinitely superior." Soraa also employs a violet LED outside the visual spectrum and a mix of three phosphors to deliver better color whereas most white LEDs mix blue light from an LED and one or two phosphors (see photo above).
"Reaching high R9 values — which factor heavily in good color rendering for skin, food, natural materials — in non-native (i.e., non-GaN) substrates and other technologies has traditionally been difficult because of efficiency limitations," Farraway said. "What GaN on GaN does is to enable better efficiencies and higher current throughput." In the spirit of fairness, Farraway noted that Seoul Semiconductor and Mitsubishi's Verbatim are also developing GaN-on-GaN processes.
Another criticism from Farraway is the reverse of that from LightingEurope: He criticizes the slow phase-in of regulations on directional lamps such as MR16 halogen products, which won't happen until 2014 and 2015. Incumbent players, like Philips, Osram, and GE, have large factories and employ many people; Farraway believes that workforce stability may have led to political pressure in delaying the requirements for LED directional lamps.
For Farraway, the real culprit that the Regulation should be addressing is the AC-mains powered MR16 lamps with a GU10 base that is often referred to as a GU10 bulb. "It is inefficient and there are options available today," he says. Although the price differential is a factor of 3.5–4 today, the price will decrease as volume increases for an affordable product that can last 40,000 hours, compared to an incandescent bulb's 700 hours.
Education, not legislation
A lax legislation will dilute lighting qualities and so disengage the end user. "We need education, through legislation," Farraway says. Another example of the dilution of quality is in the area of directional lighting, he claims. Initially, the cone angle was 30°; now it is 90°, which is not directional lighting, he contests. "This plays to the manufacturers who cannot produce a quality light into a small area, to the benefit of the [older] LED technology."
He is also mindful of the lack of policing, pointing out that although US and Asia markets may have a similar implementation to the EU, the same product from one manufacturer can, in theory, achieve different ratings in different regions, compromising the quality marks. Whether there will be an optimized-US and an optimized-EU version of products will depend on demand, he says.
Distributor Avnet Electronics, which has a lighting design service and a business arm, Avnet Abacus, specializing in lighting products, is also keen for a universality to be brought to the Regulation and industry in general. Georg Steinberger, vice president, communications at Avnet Electronics, says, "Although we cannot comment on EU policies or industry body policies, of which we are not members, it is obvious that LED technology is the lighting technology of the future... It would be desirable if the World Customs Organization and the EU would come to a technically sound and fair decision on the treatment of LEDs and LED modules, which today in many countries are classified differently and create unfair trade barriers to market participants."
All factions agree on the energy-efficiency benefits of LED bulbs and the case for using them is not questioned. With critics on both sides, the one certainty is that the different viewpoints are seemingly set to be pitted against each other in the next EcoDesign revision, although many are building up a case for their position now.