EU Ecolabel criteria revision for Lamps Commented version ... · EU-widelabel”vs.28localnationallabels) ... (LVD) Assessment and ... LED lamps have nearly identical impact on the

21 March 2014

EU Ecolabel criteria revision for

Lamps

Commented version after 2nd AHWG meeting

13th February 2014

Table of content

1) Criteria development process

2) Introduction

3) Challenges

4) Scope

5) Performance Criteria

6) Corporate and social responsibility criteria

7) Hazardous materials

8) Discussion and Conclusions

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21 March 2014 Section

Criteria development process

Stakeholder consultation

Preliminary report•Products definition•Market analysis•Technical analysis• Improvement potential

•LCA

1st AHWG

2nd Working Document•Draft criteria proposal 2nd AHWG

13 February 2014Final proposal

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IntroductionEU Ecolabel criteria for light sources (Commission Decision of 6 June2011) set through Regulation (EC) No 66/2010:• It is a Voluntary scheme• To promote the best environmental performing products, max top

10-20%• It should be workable and affordable• In order to raise environmental awareness of consumers

net balance between the environmental benefits and burdens;they shall be based on the most significant environmental impactswhich are expressed as far as possible via technical keyenvironmental performance indicators.

quality of light is to be taken into account since light is essential forlife

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Ecolabel benefits

It is an opportunity to improve the uptake of the premium (approxtop 20% lamps) and a possibility to support setting therequirements to differentiate from the minimum averageperforming products

Strengthen one independent set of rules. (The Ecolabel initiativewould reduce the proliferation of different national initiatives: “OneEU-wide label” vs. 28 local national labels)

“LED lamps quality” to support the market penetration and imageof LED lighting in the mind of consumers (refer to SSL GreenPaper)


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Challenges

Define the appropriate criteria to make a workable, overall agreed and supported Ecolabel criteria catalogue for lamps

Enhance the visibility of ECOLABEL for lamps

Achieve dynamic criteria: technology development requires frequent revision of label criteria and therefore a time limited ecolabel

Ensure competitive costs

Ensure Effective Market Surveillance of ECOLABEL for lamps


ScopeIncluded in the scope• luminous flux ≥ 60 and ≤ 12000 lumens• domestic sector with direct or indirect connection to the public electricity

supply equipped with a lamp cap listed in EN 60061 and made in order to produce a visible radiation

Not included in the scope • high intensity discharge lamps,• coloured lamps,• Low voltage (LV) self-ballasted Fluorescent lamps, • LV Incandescent lamps, • LED Tubes, LED modules, • projector lamps, photographic lighting, solarium tubes, battery driven

systems and other lamps that are not intended for lighting applications in the domestic sector

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Comments on scope

• LED tubes and modules? Why are not included?

• Could you consider to widen the scope, including also professional?

• DG ENV: will mostly oppose any change on the scope, which is meant to be technology neutral.

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21 March 2014

Performance Criteria

Criterion 1: CE compliance

Consumer interests must be assured by conformity of lamps on the market to the followingEuropean legislation:• Commission Regulation (EU) No 244/2009 on implementation of Ecodesign requirements

for non-directional household lamps• Commission Regulation (EC) No 859/2009 of 18 September 2009 amending Regulation

(EC) No 244/2009 as regards the Ecodesign requirements on ultraviolet radiation of non-directional household lamps

• Commission delegated Regulation (EU) No 874/2012 of 12 July 2012 supplementingDirective 2010/30/EU of the European Parliament and of the Council with regard to energylabelling of electrical lamps and luminaires

• Commission Regulation (EU) No 1194/2012 of 12 December 2012 implementing Directive2009/125/EC of the European Parliament and of the Council with regard to ecodesignrequirements for directional lamps, light emitting diode lamps and related equipment

• Directive 2010/30/EU on labelling and standard product information of the consumption ofenergy and other resources by energy-related products

• Directive 2011/65/EU replacing 2002/95/EC on Restriction of the use of certain hazardoussubstances in electrical and electronic equipment (RoHS)

• Directive 2006/95/EC Low Voltage Directive (LVD)

Assessment and verification: This may be by submission of manufacturers test report ofproof of compliance measured in European accredited laboratory (ISO 17025).

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Criterion 1: commentsDG ENV, DG Energy and DG Connect: we cannot have a criterion on CE compliance, as products and/orcompanies not complying with the applicable legislation cannot be awarded with the EU Ecolabel.Commission recognizes the existing problem of malfunctioning Market Surveillance, but other EU policies aretaking care of solving the issue.Moreover the CE mark means compliance unless it is proven. No legislation therefore should weaken CEmarking.In conclusion, from the legal point of view Ecolabel is not the right place to make working what is not workingin other policies, and one criterion assuming that CE marking cannot be trusted should not be included.Ecolabel should better distinguish complying and performing products, going behind ecodesign performancewhich automatically would ensure CE compliance.

Denmark: The issue that not all products comply with the legislation is not for the Ecolabel to solve.The starting point from the Ecolabel is that a product is in compliance with relevant regulation and thenEcolabel criteria come on top to differentiate the best products in respects of environmental performance, andother aspects if relevant.it is not competent bodies’ duty to evaluate CE compliance but the task of market surveillance to enforceregulations. Third party test reports would mean extra costs for applicants.

Austria: in principle legal compliance is a pre-condition for the Ecolabel. However the packaging of a lampshould be checked if the declaration is complete e.g. according Reg. 874/2012/EC, because this declarationis an essential information for consumers.

General conclusion: to remove criterion 1.

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Criterion 2: Luminous efficacy

Luminous Efficacy: Energy Efficiency Class A++, according to Annex VIand VII of Commission delegated Regulation (EU) No 874/2012 at 1000hrs based on lumen and wattage measurement.

Luminous efficacy is the efficiency of a lamp to convert energy to light(expressed in lumen/watt, lm/W). The higher the value the more efficientthe lamp is. Whilst this is not the only efficiency concern, how much light isproduced and how the light is distributed will also affect installed efficiency,it is a simple and easy to understand metric that is also easy to verify bysimple measurement.

Assessment and verification: This may be by submission ofmanufacturers test report of proof of compliance measured in Europeanaccredited laboratory (ISO 17025) .

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Criterion 2: commentsADEME: from LCA results it is evident that LED lamps are competitive to CFLi lamps today. Thus 80 % ofenergy can be saved by using CFL or LED lamps. LED lamps have nearly identical impact on theenvironment compared to CFL.It would be better to set limits with “A +” because “A ++” is too ambitious and is cutting out CFLi lamps.Can you consider differentiating the CFL/LED criteria? Through lifetime for example? E.g. 4E Annex dividesand sets different limits for different technologies.Emilie will check if it is possible to differentiate the two technologies and will send input to Ecolightingconsortium.LED is still too expensive; therefore CFLi lamps should be also in the scope.In general there are not enough information given from industry side to judge if “A ++” is adequate! Alsomarket penetration data are missing.

C Briatore refers to Annex I of the background report and reminds that “even if today fewer products wouldachieve A++ (actually none, and probably also still none by start 2015), the A+ class is already nowoverpopulated and setting up the energy level at A+ would be in contradiction with the intention of Ecolabel torepresent approximately the top 10-20 % of the high quality market”.

DG Envi: the top 10-20% should be already available at the time of setting up of the criteria.

General comments from stakeholders: Why at 1000 hrs?Industry: at 0 it is easy to achieve – at 1000 you can better judge the quality. At 2000 would not be measuredby Market Surveillance Authorities.

BEUC/EEB: would support “A ++” but more market data are needed; more transparent process and data.

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Criterion 3: Lumen maintenance and early failures

Lumen maintenance and early failures (acc. EN 62612 / IEC 62612, 2013-06): Lumenmaintenance factor x at 1000 hrs ≥ 0,95 and no failures for all lamps.

The useful life of a lamp may be defined using the following parameters.• The lumen maintenance related lifetime parameter (Lx) predicts the percentaged lightoutput (x) of a lamp after a defined time period (rated life, e. g. 15000 h) compared to thelight output at new. Example: L70 at 15000 hours implies that after 15000 hours at least70 % of the initial light output will be provided by those lamps that haven’t failed.• The failure parameter Fy (with failure fraction y) expresses the combined effect of allcomponents of a lamp including mechanical, electrical etc. as far as the light output isconcerned. The F parameter includes abrupt failure (complete or catastrophic failure withno light output) and a deterioration of light output below the rated level (e. g. 70 %). So avalue F50 at 15000 hours implies 50% of the lamps will still be supplying at least xpercent light after 15000 hours.

Assessment and verification: This may be by submission of manufacturers test reportof proof of compliance measured in European accredited laboratory (ISO 17025).

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Criterion 3: comments

Industry will provide the graph to explain why “at 1000 hrs” instead of6000hrs as stated in the ecodesign regulation.

6000hrs is too long to be tested by MSA.

Within ecolabel each product carrying the label has been tested by thirdparties labs, this is the big change/difference with ecodesign.

Commission: misunderstanding because we are arguing and basingthe criteria on Market Surveillance Authorities issues, and third partycertification is already foreseen in the current ecolabel regulation.

BEUC/EEB: from a different report (to be sent to Ecolightingconsortium) it comes out that concerning failures 1000 hrs is not such arelevant for testing because eventual the problems were arising onlyafter 5000 hrs.

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Criterion 4: Color rendering index

Colour rendering index (CRI):

CRI ≥ 85, initial (0h) and maintained at 1000 h

Assessment and verification: This may be by submissionof manufacturers test report of proof of compliancemeasured in European accredited laboratory (ISO 17025).

Compliance:

For all tested units in a sample the measured CRI valuesshall not decrease by more than 3 points from the requiredCRI value.

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CRI: in USA energy star they have been using further parameter (r)

Very technical issue not to be discussed here

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Criterion 5: Colour consistency

Colour consistency

To be measured initial (0h) and maintained at 1000 h

All lamps shall fall within an ellipse of 5 SDCM, initial andmaintained (0 and 1000 hours).

Assessment and verification: This may be by submissionof manufacturers test report of proof of compliancemeasured in European accredited laboratory (ISO 17025).

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Agreed to change “SDCM of 5” to “SDCM of 3”.

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General comments on performance criteria

DG ENV:Assessment and verification: to be corrected/adapted.No need to repeat for each criterion “This may be by submission ofmanufacturers test report of proof of compliance measured in Europeanaccredited laboratory (ISO 17025)” because Regulation 66/2010 on EUEcolabel at Art. 4, n.4 already states “Competent bodies shall ensure thatthe verification process is carried out in a consistent, neutral and reliablemanner by a party independent from the operator being verified, based oninternational, European or national standards and procedures concerningbodies operating product-certification schemes”.

Moreover Article 9(7) of the EU Ecolabel Regulation refers that:"Competent bodies shall preferentially recognize tests which areaccredited according to ISO 17025 and verifications performed by bodieswhich are accredited under the EN 45011 standard or an equivalentinternational standard (…)", which means that when test reports areforeseen as an assessment and verification requirement, they shouldpreferably accredited according to ISO 17025.

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CRITERION ECODESIGN ECOLABEL (proposed by Ecolighting)

Conformity CE Declaration of Conformity CE Declaration of Conformity

Luminous Efficacy NDLS Clear :

Pmax=0,6*(0,88√Ф+0,049Ф)

NDLS Non-Clear :

Pmax=0,24√Ф+0,0103Ф

DLS: EEI ≤ 0.20 @ 0h

(all values relate to 2016)

NDLS: EEI ≤ 0.11 @ 0 h and @ 1000 h

DLS: EEI ≤ 0.13 @ 0 h and @ 1000 h

(i.e. min A++ for DLS and NDLS, initial and

maintained)

Lumen Maintenance factor ≥0.8 @ 6000h ≥0.95 @ 1000 h

for all lamps

Lamp Survival factor ≥0.9 @ 6000h 1.0 @ 1000 h

for all lamps

Colour Rendering Index ≥80 @ 0h ≥85 @ 0 h

≥85 @ 1000 h

Colour Consistency Average of 20 lamps within 6

SDCM @ 0h

All lamps within 5 SDCM

@ 0 h

Colour Stability over Life No requirement All lamps within 5 SDCM

@ 1000 h (no shift)


21 March 2014

Corporate and social responsibitily criteria

Criterion 9: Packaging

Packaging:

o Laminates and composite plastics shall not be used.

o Where cardboard boxes are used, they shall be made of 80 %post-consumer recycled material.

Assessment and verification: a sample of the productpackaging shall be provided on application, together with acorresponding declaration of compliance with this criterion. Onlyprimary packaging, as defined in European Parliament andCouncil Directive 94/62/EC, is subject to the criterion.

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PlasticsEurope: old criterion, redundant, and laminates are not used. It is fully recognized that“packaging and end-of-life, are negligible in the total life-cycle perspective”.We do not see any technical, physical or mechanical reason for the use of these plastics forthis simple packaging application. PET and other plastics are used for packaging of lamps.Since laminates and composite plastics are not used, these cannot have an environmentalimpact so there should not be a criterion on this otherwise there is a breach of the rules laiddown in the Ecolabel Regulation saying that criteria should address major environmentalimpacts.Laminates and composite plastics are discriminated without any proof based on life cycleanalysis showing that the use of laminates and composite plastics results in a higherenvironmental impact than non-laminated plastics. The opposite could be true becauselaminates and composite plastics may be much more resource efficient than single polymerplastics.For these reasons we ask to remove “Laminates and composite plastics shall not be used.”

General comments: If the packaging is not relevant and has a negligible environmental impact(see LCAs), why should we keep this criterion?

Stakeholders: ecolabel should not just repeat what is foreseen in other legislations; the criterionon packaging has an added value.

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Criterion 10: Recycling

Collection & Recycling:

The manufacturer shall implement appropriateenvironmental measures to reduce and recover the wastethat is produced during the installation of a new orrenovated lighting system. All waste lamps shall beseparated and sent for recovery in accordance with theWEEE directive (2012/19/EU).

Assessment and verification: a declaration describinghow the waste will be separated, recovered or recycledshall be provided.

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If it is already implemented with the WEEE directive, what is the purpose of this criterion?

Furthermore the enforcement can’t be checked, it is MS duty.

Agreed: criterion to be deleted

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Criterion 11: Social accountability

Social accountability:Fundamental principles and rights regarding working conditionsmust be fulfilled during the production of the Ecolabelled lightsource.The licensee must ensure that the production of the light sourcefollows the ILO conventions regarding child labour, forced labour,health and safety, discrimination, discipline, hours of work,wages, freedom of association and collective bargaining.

Assessment and verification: the applicant shall declarecompliance with this requirement and provide a specification ofcontracts with inspection authorities and either a code of conductregarding ILO conventions or a SA8000 certification.

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Criterion 11: commentsDG ENV: To be substituted with the new harmonized text proposal:

“Applicants shall ensure that the fundamental principles and rights at work as described in the International Labour Organisation’s (ILO) Core Labour Standards, the UN Global Compact and the OECD Guidelines for Multi-National Enterprises shall be observed by all production sites used to manufacture the licensed product(s). For the purpose of verification, the following ILO Core Labour Standards shall be referred to:029 Forced Labour087 Freedom of Association and Protection of the Right to Organize098 Right to Organize and Collective Bargaining100 Equal remuneration105 Abolition of Forced Labour111 Discrimination (Employment and Occupation)138 Minimum Age Convention155 Occupational safety and health182 Elimination of the Worst Forms of Child LabourThese standards shall be communicated to production sites along the supply chain used to manufacture the final product.

Assessment and verificationThe applicant shall demonstrate third party verification of compliance, using independent verification or documentary evidence, including site visits by auditors during the Ecolabel verification process for production sites in the supply chain for the licensed products. This shall take place upon application and subsequently during the license period if new production sites are introduced”.

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Criterion 12: Information appearing on the EU Ecolabel

Optional label with text box shall contain the following text:Expiring date of the label, orAwarding date of the label

If the light source does not contain mercury, the optional label maystate that the light source does not contain mercury.The guidelines for the use of the optional label with text box can befound in the ‘Guidelines for use of the Ecolabel logo’ on the website:“…..”Assessment and verification: the applicant shall provide a sample ofthe label, together with a declaration of compliance with this criterion.

Rationale: LED technology development especially requires frequentrevision of label criteria and therefore a dynamic label!

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Denmark and ADEME: No mercury mention.

DG ENV: the EU Ecolabel Regulation doesn't foresee adynamic approach in respect with the optional text box.

When an EU Ecolabel product is placed on the market thenyou do not have to take it back from shelves even if theecolabel licence has expired.

DG Energy: on warehouse of e.g. Philips is NOT place onthe market; only when products are on the warehouse ofretailers they are considered to be placed on the marketand can be sold.

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21 March 2014

Hazardous materials

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Mercury in single ended CFL with average mercury content of less than1,5 mgMercury in double ended FL lamps with average mercury content of lessthan 3,0 mg

Assessment and verificationTest report, IEC 62554 for sample preparation, IEC 62321 formeasurement

According to ErP Directive the avarage mercury content is public andhas to be printed on the packaging. In the total environmental impact offluorescent lamps, mercury is just a small component. The majority ofimpacts are accounted to the energy use during the use phase.Therefore it is suggested that the Ecolabel mercury content remainsthe same and represents an average value.

Criterion 6: Mercury



Denmark: The energy consumption in the use phase is so dominant that all other factors will look minor. Butthis is not an argument for disregarding the environmental impact of the use of mercury. Not consideringmercury will also not take the political and consumer concerns in Denmark into account.DK has previously argued for mercury-free eco-labeled light sources (at least lamps with single-ended, i.e.replacement of mercury-containing CFLs).Given that:1. there is a technology (LED) that can substitute mercury-containing CFLs,2. LEDs are more energy efficient,3. the collection of mercury-containing lamps is not as efficient (max 50% in EU). This means a hugediffuse pollution of local environment where disposed of, and migration into the environment.4. the recycling of mercury from the sparse collection of light sources are not impressive (going on at all?It is understood that most is deposited). This means depositing huge amounts of EEE with a little butsignificantly amount of mercury,5. mercury is classified as Toxic and Hazardous (conflict with Articles 6 (3b), (6) and Article 6 (7))the EU Ecolabel shall substitute hazardous substances, wherever technically possible to substitute.

Denmark proposes and will probably also require an exclusion of the use of mercury, at least in EUEcolabelled single-ended light-sources.It must be realized that an exclusion of mercury will be an important platform that the Ecolabel canuse to market itself. Marketing is about clear messages, and it is less likely to have success with marketinga product as “reduced environmental impact …”, “less content of mercury” etc.

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Criterion 7: current formulation1) In accordance with Article 6(6) of Regulation (EC) No 66/2010, the product or any partof it shall not contain substances referred to in Article 57 of Regulation (EC) No1907/2006 nor substances or mixtures which may be or have been assigned thefollowing hazard statements or risk phrases. (List of hazard statements and risk phrases).

2) The use of substances or mixtures which upon processing change their properties(e.g. become no longer bioavailable, undergo chemical modification) in a way that theidentified hazard no longer applies are exempted from the above requirement.

3) Concentration limits for substances or mixtures meeting the criteria for classificationwith the above mentioned hazard classes or categories, and for substances meeting thecriteria of Article 57(a), (b) or (c) of Regulation (EC) No 1907/2006, shall not exceed thegeneric or specific concentration limits determined in accordance with the Article 10 ofRegulation (EC) No 1272/2008. If specific concentration limits are determined theyshould prevail against the generic ones.

4) Concentration limits for substances meeting criteria of Article 57(d), (e) or (f) ofRegulation (EC) No 1907/2006 shall not exceed 0,1 % weight by weight.

5) The following substances/uses of substances are specifically derogated from thisrequirement: Homogenous parts with weight below 5 g; All hazard statements and riskphrases listed above.


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Identified bottlenecks

In paragraphs 4 and 5 the following problems are identified:

4) “Concentration limits for substances meeting criteria of Article 57(d), (e) or (f) of Regulation (EC) No 1907/2006 shall not exceed 0,1 % weight by weight”..

the basis of the concentration limit is missing

5) Notion of “homogenous part”

not defined


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Criterion 7: Hazardous materialsParagraph 4 and 5 is to be changed as follows:

Option 1

“Concentration limits for substances meeting criteria of Article 57(d), (e) or (f) of Regulation (EC) No 1907/2006 shall not exceed 0,1 % weight by weight [in homogenous material].”

“The following substances/uses of substances are specifically derogated from this requirement: Homogenous material; all hazard statements and risk phrases listed above”.

Option 2

“Concentration limits for substances meeting criteria of Article 57(d), (e) or (f) of Regulation (EC) No 1907/2006 shall not exceed 0,1 % weight by weight [in parts above 5 g].”

“The following substances/uses of substances are specifically derogated from this requirement:

[Parts] with weight below 5 g; all hazard statements and risk phrases listed above”.


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Option 1

When the wording homogenous material is chosen a well-defined expression is used(according to RoHS). The conditions are strict. The use of hazardous substances is reduced tothe minimum. At the same time, however, the implementation becomes extremely difficult,because of the large number of homogenous materials, and the lack of complete data in thesupplier chain, e.g. confidentially information on composition.

Option 2

When opting for a derogation, which is based on the weight of a product part, theimplementation becomes easier. Majority of the parts do not have to fulfil strict conditions, andcan contain hazardous materials without limitation. In case of lamps the majority of componentsare below 5 g, typically the electronic parts. Heavier parts are the plastic casing, the optics andaluminium heatsink. The disadvantage of this kind of derogation is, however, that the electronicpart, which is responsible for the highest environmental impact during manufacturing, isexcluded. This approach puts on stake the ultimate goal of Ecolabel: to reduce negativeimpacts during consumption and production by focusing on the most important environmentalimpacts.

Rationale for Option 1 and 2


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Lamp parts Halogen CFL LED retrofit

Glass One part, homogenous material>5g

Homogenous material>5g

n/a

Optics n/a n/a One homogenous material <, >5g

Plastic housing(plastic mould,brominated flame retardants)

n/a One part,homogenous material>5g

One part,homogenous material>5g

Socket parts(aluminium, solder, brass, glue etc.)

Homogenous material <5g

Homogenous part <5g Homogenous part <5g

Electronics(printed circuit board, copper, plastics, flameretardants, etc.)

n/a Consisting of several components homogenous material < 5g

Consisting of several components homogenous material < 5g

Aluminium heat sink n/a n/a One part, homogenous material>5g


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Criterion 7: Hazardous materials


Substance Current condition for derogation Options for new criteria New verification Justification / Remarks

Any substance or mixture with listed R-phrases (Mentioned in Criterion 5)

which change their properties in a way that the identified hazard no longer applies

No change For each part above 5g the applicant shall provide declaration of compliance

Hazard classes(Mentioned in Criterion 5)

shall not exceed the generic or specific concentration limits determined in accordance with the Article 10 of CLP

shall not exceed the generic or specific concentration limits determined in accordance with the Article 10 of CLPin part above 5g

For each part above 5g the applicant shall provide declaration of compliance

The assessment and verification and the compliance level should be the same.It would weaken the current criteria and Ecolabel, though.

CarcinogenicMutagenicReprotoxic substances identified in category 1 and 2(substances meeting the criteria of Article 57(a), (b) or (c) of REACH)

shall not exceed the generic or specific concentration limits determined in accordance with the Article 10 of CLP

shall not exceed the generic or specific concentration limits determined in accordance with the Article 10 of CLPin part above 5g


The assessment and verification and the compliance level should be the same.

It would weaken the current criteria and Ecolabel, though.

PBTvPvBendocrine disruptorsnot identified according to category 1 or 2 but with same level of concern

(Substances meeting criteria of Article 57(d), (e) or (f) of REACH)

shall not exceed 0,1 % weight by weight

shall not exceed 0,1 % weight by weight in homogeneous material

Or

shall not exceed 0,1 % weight by weight in part above 5 g


The basis of concentration was not specified which created legal uncertainty. With this addition the condition can be fulfilled and the legal uncertainty disappears.

Or


All hazard statements and risk phrases listed in Criteria 5

Homogeneous parts with weight below 5 g

Homogeneous material with weight below 5 g

Or

shall not exceed 0,1 % weight by weight in part above 5 g

No change There is no definition for homogenous part, which creates legal uncertainty. Therefore we propose to use the expression homogenous material, which is a well defined in RoHS.

Or


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“No derogation from the exclusion in Article 6(6) shall be given concerningsubstances identified as substances of very high concern and included in thelist set out in Article 59 of Regulation (EC) No 1907/2006, present in mixtures,in an article or in any homogenous part of a complex article in concentrationshigher than 0,1 %. Specific concentration limits determined in accordance withArticle 10 of Regulation (EC) No 1272/2008 shall apply in case it is lower than0,1 %.

Assessment and verification: the list of substances identified as substancesof very high concern and included in the candidate list in accordance withArticle 59 of Regulation (EC) No 1907/2006 can be found on the website:http://echa.europa.eu/chem_data/authorisation_process/candidate_list_table_en.asp

Reference to the list shall be made on the date of application.

Criterion 8: SVHC substances


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Criterion 8: SVHC substances

No change proposed

Criterion 8 is the repetition of the requirement of Article6.7 of the Ecolabel Regulation, therefore not possible tochange!

SVHC substances are prohibited!

SVHC can be present only in concentrations less than 0,1% in homogeneus part = homogenous material accordingto RoHS


Criteria 7 and 8: comments

Denmark: We welcome the two options suggested. Especially we hope tobe able to finds ways to lower the administrative burden. Denmark istherefore prepared to derogate for several of the chemical demands, ifmercury is excluded in CFL’s.It is emphasized that derogation cannot be done with regards to Candidatelist substances.Denmark also proposes to exclude all brominated flame retardants in theouter chassis of the light source.

All stakeholders: in addition to the information provided on the number ofcomponents/homogeneous materials for each different lamp types(Halogen, CFL and LED retrofit), it would be interesting to know theirweight and more qualitative information (e.g., constitution, such as metals,alloys, polymers, glass and additives, coatings or treatments applied), inorder to understand the rationale behind the proposal to keep a thresholdof 5 g.Based only on weight is not enough, concluded by JRC methodologyList of parts subjected to derogations and screening of the parts is missing!

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Criteria 7 and 8: comments

Ecolighting consortium:

We acknowledged that a list of parts subjected toderogations and screening of the parts is missing.

We are thinking how to tackle and will contact JRC forexperiences.

Nevertheless SVHC cannot be derogated.

Homogeneous part is homogeneous material.

Creating a new definition in the Commission Decisionwould not solve the legal uncertainty.

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Justification• There is no need to repeat the criterion 5 and 6 specially for plastics.

This only increases the administrative burden without anyenvironmental benefit.

• Plasticisers (e.g. phthalates) are only used in some cables and in suchsmall quantities that they do not represent a significant environmentalimpact compared to energy use.

• Phthalates have been risk assessed and should be treated as any othersubstance in accordance with criterion 5 and 6.

• With regard to PVCs, the result of keeping this criterion would be theexclusion of some kinds of PVC while other kinds of PVC would complywith this criterion.” This appears to be illogical. PVC should be alsotreated as any other material in accordance with criterion 5 and 6.

Plastic parts (old criterion 7): to be deleted


Plastic parts: comments

Denmark does not agree to delete the criterion on plastic. But we think the opinion of Plastic Europe is useful and hopefully these can be used to improve the criterion.

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21 March 2014

Discussion & Conclusions

LCA

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• The greatest environmental impacts of lamps and luminaires are due to the electricity consumption. ~90%

Conclusions from LCA

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“Efficient use” of the lamps should be encouraged, so that the lighting is provided when and where needed with the lowest possible energy consumption, including intelligent use of lighting:

• Correctly commissioned lighting controls (daylight, occupancy)

• Luminaire design to improve the light output from the luminaire

• Lighting design so that the light is provided where it is needed

• Well managed and maintained installation

Ecolabel: real barriers1. The Hazardous Substances criteria are not workable because:

• Missing definition of Homogeneous material

• Incoherent wording between REACH and Ecolabel

• Mission impossible to track all substances (supply chain)

• REACH parameters changing every 6 months

2. The high costs of filing the label application do not present a viableinvestment for manufacturers

3. Market Surveillance actions against misuse of the label are very“light”

4. The fixed life time of the label leads to high costs at “end of labellife”

5. LED technology is evolving fast and would need a dynamic label,whose criteria change annually to award only the top 10-20% of themarket

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Barriers for uptake of Ecolabel

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• The expression „homogenous part” is not defined in the regulation

• It can be only interpreted as „homogenous material” as in RoHS

• SVHC list is updated 2x/year by ECHA

• Information flow is slow• Development time of lamps is long

• It is impossible to receive informaiton on SVHC content in all homogenous material

• High IT database demand• Supplier dependence• Responsibility is with the applicant of Ecolabel

• All electronics components contain SVHC

• E.g.: LED retrofit: 150 components, 1500 homogenous material, 50 supplier: 11,25 million safety data sheet

• Changeing suppliers, changeing composition of parts

• Changing list of substances

Large and changeing database Lack of information

Lack of definitionMoving target

Conclusions

1. The validity of Ecolabel criteria for light sources has beenextended until 31st December 2014

2. Ecolighting consortium has at the moment a critical view onthe implementation

3. The Hazardous Substances criteria (SVHC) cannot besolved. In practice not possible to fulfill: interpretation,information flow etc. Too high uncertainty to come toworkable criteria!

4. Should the revision of the Ecolabel Regulation 66/2010address the issue?

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Thank you very much for your attention!Thank you very much for your attention!

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EU Ecolabel criteria revision for Lamps Commented version ... · EU-widelabel”vs.28localnationallabels) ... (LVD) Assessment and ... LED lamps have nearly identical impact on the

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