Increasing the level set for energy efficiency requirements of products designed with LED technology is beneficial not only for the consumer, but also for the environment, for society and for the competitiveness of Europe’s industry.
Three legislative initiatives impacting lighting products are currently underway (see Annex II for details), with major changes expected compared to current legislation:
• Eco-design requirements for light sources
• Energy labelling requirements for light sources
• RoHS exemption renewal requests
We, the undersigned associations, support the objectives of Eco-design, Energy labelling and RoHS.
We call on regulators to adopt a pragmatic and realistic transition timetable to substitute lighting technologies and products. This timetable needs to respect the established maintenance and repair cycles of the end-users of these lighting products.
Markets need sufficient time to understand and evaluate alternative lighting products and to then adjust their budgets and replacement cycles. A premature phase-out may lead to unnecessary waste and costs.
The transition period needs to allow affected companies to build new manufacturing facilities, to train workers and to help them make the transition from one professional environment to another (see Annex I).
Where there are no substitute products and technologies, we call on regulators to continue to allow special purpose products on the EU market by exempting them from the Eco-design rules and renewing the exemptions under RoHS.
In the interest of a robust and balanced impact assessment, we call on the European Commission to take into account the input received from all stakeholders across the value chain (from lighting manufacturers to installers and end users) and under both legislative processes (consultations under RoHS and Eco-Design).
Download the full statement here.