The EU Lightbulb Ban

1. The EU Lightbulb Ban RevisedversionApril2015 Friday 24 April 15

2. 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. Friday 24 April 15

3. 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 Friday 24 April 15

4. Lamp Technologies Friday 24 April 15

5. Luminescent LightLuminescent Light Gas Discharge (FL tube, CFL, HID) Solid State Lighting (LED) Incandescent LightIncandescent Light Incandescent Halogen Electric Light Categories Friday 24 April 15

6. Light Quality Friday 24 April 15

7. Incandescent Light Natural, radiating light Produced by heating a ﬁlament Luminescent Light Synthetic 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 Friday 24 April 15

8. Incandescent light and sunlight are “the two ‘golden standards’ of lighting” - Global Lighting Association Incandescent Light Always top quality, just like sunlight Friday 24 April 15

9. Incandescent Light Naturally full-spectrum Luminescent Light Not full-spectrum Complete spectrum with all colours visible Gaps with many wavelengths missing Friday 24 April 15

10. Full-Spectrum Light Perfect colour accuracy Colour Rendering Index 100 = lossless Non-Full-Spectrum Light Poorer colour accuracy CRI only 80-85 = lossy Friday 24 April 15

11. 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 Friday 24 April 15

12. 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) Friday 24 April 15

13. Light Colour Friday 24 April 15

14. Incandescent Light Colour A glowing tungsten ﬁlament radiates a natural warm white light. Luminescent Light Colours A 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. Friday 24 April 15

15. Soft, warm, and naturally ﬂattering Incandescent Light Makes human skin look glowing and healthy CFL & LED Light Makes human skin look pale and dead Photo: Wikimedia Soft, warm, and naturally ﬂattering Any imperfections get harshly highlighted Friday 24 April 15

16. Function “thereshallbenosignificantnegativeimpactonthe functionalityoftheproduct,fromtheperspectiveoftheuser” - The Ecodesign Directive Friday 24 April 15

17. CFL & LED Only some are dimmable Incandescent & Halogen All 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 Friday 24 April 15

18. 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 Friday 24 April 15

19. Energy “The product shall present significant potential for improvement in terms of its environmental impact without entailing excessive costs” - The Ecodesign Directive Friday 24 April 15

20. ElectricityHome Energy Light Incandescent Home Energy Use EU-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 2008 2. European Commission, Residential Lighting Consumption and Saving Potential in the Enlarged EU 3. VITO 2007 (p. 69, table 2-11) Transport 33% Industry 27% Services 13% Households 25% Friday 24 April 15

21. Heat/Light Ratio The 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% Heat Light CFLs and LEDs produce heat too, though less, and mostly internally. Friday 24 April 15

22. 0% 20% 40% 60% 80% 100% Incandescent CFL ‘Wasted’ Heat Useful Indoor Heat Light 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 houses 2. 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 Friday 24 April 15

23. Incandescent Lamps Optimal Power Factor (1.0) CFL & LED Lamps Lower 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 Friday 24 April 15

24. EU Power Factor Requirements For the consumer market, the minimum PF requirements are surprisingly slack: CFLsCFLs 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 Requirements Power 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 Friday 24 April 15

25. 0 5 10 15 20 25 30 15W CFL 12W LED Watts Volt-amperes Ballasts (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 Friday 24 April 15

26. 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. Friday 24 April 15

27. 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 Paradox Viva LasVegas: 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? Friday 24 April 15

28. 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 Friday 24 April 15

29. 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 Friday 24 April 15

30. Incandescent Life Originally 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 Life Halogen 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 Friday 24 April 15

31. LED Life Rated 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 Life Rated 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, JiY.,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 Scenario The great LED lightbulb rip-off: One in four expensive 'long-life' bulbs doesn't last anything like as long as the makers claim Do 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. Friday 24 April 15

32. 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 ? ? Friday 24 April 15

33. • 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. Friday 24 April 15

34. 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! Friday 24 April 15

35. Environment “Health, safety and the environment shall not be adversely affected” - The Ecodesign Directive Friday 24 April 15

36. 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 Friday 24 April 15

37. General Electric, Osram-Sylvania, Home Depot, LiteTronics.com, MineralsCoalitionEducation.com LED Complex 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) CFL Complex 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 Friday 24 April 15

38. 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 Friday 24 April 15

39. One kg can poison 15 lakes. CFL Mercury One 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! Friday 24 April 15

40. 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 Friday 24 April 15

41. Rare Earth Phosphors LEDs 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: LiamYoung/Unknown Fields The dystopian lake filled by the world’s tech lust (BBC) Earth-Friendly Elements, Mined Destructively (NewYork Times) Friday 24 April 15

42. 1. Potential Environmental Impacts from the Metals in Incandescent, CFL, and LED Bulbs 2. 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 Metals CFLs 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 Friday 24 April 15

43. Summary Environment Life 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) Friday 24 April 15

44. Health Friday 24 April 15

45. S Mercury in Production Hazardous for miners, for the environment, and for workers in manual CFL factories. Sweat shop in India (screenshot from Austrian documentary Bulb Fiction) “LargenumbersofChineseworkershavebeenpoisonedbymercury, which forms part of thecompactfluorescentlightbulbs. Asurgeinforeign demand,set off byaEuropean Union directivemakingthesebulbscompulsorywithinthreeyears, has also ledto thereopeningof mercury minesthathaveruinedtheenvironment.” ‘Green’ lightbulbs poison workers (TheTimes) Friday 24 April 15

46. 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 Home Mercury 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? Friday 24 April 15

47. U.S. EPA Cleanup Guide 1. Before cleanup a. 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 cleanup a. 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 cleanup a. 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. Friday 24 April 15

48. EU The 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. Friday 24 April 15

49. 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 Friday 24 April 15

50. Flicker Lamps 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. Friday 24 April 15

51. Glare The 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! Friday 24 April 15

52. 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 InVitro 2. 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) Friday 24 April 15

53. LED Blue Light Hazard LED 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 Friday 24 April 15

54. 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.” Friday 24 April 15

55. Groups Especially at Risk Groups 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.” Friday 24 April 15

56. Blue Light Bio-Disruption Blue-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 Clock Too little light in the day, and not enough darkness at night: How our sleep patterns are changing for the worse Friday 24 April 15

57. General Health & Wellness Besides 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! Friday 24 April 15

58. EM Emissions & Safety Most 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 2011 2. More LED Issues 3. Philips Recalls 99,000 LED Light Bulbs Due to Shock Risk 4. 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 Friday 24 April 15

59. Summary Health Risks Potential 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. Friday 24 April 15

60. EC Documents Friday 24 April 15

61. The Ecodesign Directive The 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. Friday 24 April 15

62. The BiasedVITO Study Dutch consultantsVITO’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

63. The Misleading Technical Brieﬁng As 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

64. The Halogen Lie While the halogen phaseout scheme was given on the EU page for lighting professionals... Friday 24 April 15

65. 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

66. 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

67. Effects of Bulb Ban Friday 24 April 15

68. Consumer Confusion Friday 24 April 15

69. Incandescent Simplicity When buying a new light bulb, wattage used to be all you needed to know. Puzzling Lamp Jungle Now 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

70. Not Interchangeable Same top light qualitySame top light quality Lower quality, different functionalityLower 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

71. • 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

72. • 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

73. 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

74. Conclusion 1.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

The EU Lightbulb Ban

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