EU Ecodesign regulations and the impact on DOPs and production in the EU
The European Union (EU) is proposing a new set of regulations governing lighting which, if passed as they currently stand, would dramatically affect all of the equipment used for entertainment lighting (including tungsten, arc and LED fixtures). These new regulations are intended to start from 1 September 2020. If implemented as written, the new rules would heavily impact all areas of entertainment lighting and all who work in this field – lighting creators, lighting users and lighting manufacturers.
ALD, ABTT and PLASA have submitted responses. The ALD then set about alerting the theatrical community across Europe to the problem. (Association of Lighting Directors, Association of British Theatre Technicians, Professional Lighting and Sound Association).
The first thing to note is that none of this is entirely new. For some years now, the EU has been working to introduce “Ecodesign” regulations aimed at forcing manufacturers to reduce the power consumed by their products, ideally by making them more energy efficient (i.e. achieving the same end result while using less power).
For lighting, the regulation currently in force is called EU1194/2012 “Implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for directional lamps, light emitting diode lamps and related equipment”
That this regulation has not affected entertainment lighting is because it includes a specific exemption: article 2 section 4(b) ii, “lighting applications where the spectral distribution of the light is adjusted to the specific needs of particular technical equipment in addition to making the scene or object visible for humans (such as studio lighting, show effect lighting, theatre lighting)”. The same “studio lighting, show effect lighting, theatre lighting” exemption was also included in a later regulation, 2015/1428, which amended two earlier regulations (224/2009 non-directional household lamps, 245/2009 products normally used as street lighting and office lighting): https://bit.ly/2Hx58XP and https://bit.ly/2Hwp5Oj.
The 2015 regulation seems to be an admission that progress in lamp technology had not been as fast as the EU had hoped, noting that “it does not appear to be economically feasible for manufacturers to develop and place on the market from 1 September 2016 onwards” lamps meeting the demands of the regulations that would be in place at that time. It therefore refined those demands but, crucially, kept the “studio lighting, show effect lighting, theatre lighting” exemption.
The date for the full implementation of regulation 244/2009 was subsequently (by a vote on 17 April 2015) revised again, to September 2018, the first time the EU rolled back an agreed product efficiency measure.
To be clear: products that do not meet a standard of 85 lm/W (in addition to the other requirements, and unless specifically exempted) will not be allowed to be supplied in the EU.
The rules cover light sources (this being a lamp or a self-contained fixture capable of producing light) with a defined (and wider than previously) chromacity range, and a luminous flux between 60 and 82,000 lumens. The lower limit is intended to exclude things like status display, pilot and decorative lamps. The EU notes in its Explanatory Memorandum that the upper limit is intended to exclude “very powerful lamps for e.g. sports lighting, theatre-, stage- and studio-lighting” (adding that “higher efficiency (LED) lamps are not (yet) readily available for these high power lamps, while users tend to be professionals that already pay attention to energy efficiency”. Unfortunately, the range specified actually does include the vast majority of light sources in use in film and entertainment lighting today, up to and including about 800W HMI and 3KW tungsten.
The output of the majority of fixtures used in film and TV production would fall between 6,000 and 100,000 lumens per Watt.
To be clear: the EU is not proposing specifically to “ban” tungsten. It’s just that most tungsten sources used in entertainment lighting sit within this output range but do not meet the energy efficiency requirements (and deliberately so: in the Explanatory Memorandum, the EU notes that “the proposed Regulation... applies the same energy efficiency requirements to all these light sources, but only LED light sources can meet them. This implies e.g. that halogen lamps will no longer be able to enter the market from the application date of this Regulation onwards”). As an example, a 230V 575W tungsten Source Four in open white outputs about 7489 lumens, so is 7489/575=13 lm/W. Even the HPL lamp itself outside the fixture outputs 11780 lumens at 575W, so is just 20 lm/W. The light source here is the lamp rather than the fixture, but if the lamps are no longer available the fixture becomes worthless. But to make it clear that this is not just an issue with tungsten sources, take the example of a much newer lightsource: the ETC Source Four LED Lustr2: with all emitters at full it is outputting 5,882 lumens and drawing 160W. That’s 36.7 lm/W. Which still doesn’t meet the minimum requirement of 85 lm/W. Moving lights? A Mac Viper Performance: 26,000 lumens, 1,000W, so 26 lm/W. The LED alternative? Encore Performance CLD (cool white), 11,600 lumens from the fixture, 580W, so 20 lm/W (even using the figures of 39,400 lumens/468W from the LED engine in isolation still only gets to 84.2 lm/W) – all still short of the target. There is also a warm white version of the Encore (the WRM); for that the figures are 9,200 lumens from the fixture (so 9,200/580=15.8lm/W), 31500 lumens from the LED engine (31,500/468=67 lm/W), an indication that warm white LEDs are currently less efficient than cool white.
To compound the issue, the new regulations also impose a limit on “standby power” of just 0.5W when not emitting light. This is really intended for devices that can go into “deep sleep” where a few moments to respond to a turn-on command are not critical. Film and entertainment lighting fixtures are unlikely to be able to meet this standard, as they have to be active listening to show data (DMX or similar) and able to respond immediately; moving lights may also be active (moving to a new position) even if not actually lit. But here’s the real reason this is all a problem: completely absent from the proposed new regulations are all of the clauses exempting “studio lighting, show effect lighting, theatre lighting” that are found in the current regulations.
Annex 1 of the regulations includes exemptions for “image capture and image projection (including, but not limited to, photocopiers and video projectors)”. One could argue that we are projecting light onto a set or stage (or we could put a gobo in every profile and call that projection), but it is tenuous. Light sources “with a beam angle of less than 10˚” are also exempt, but purchasing 5˚ fixtures and then just swapping the lenses seems wasteful...
Annex 6 – Benchmarks includes the comment that “features required in certain applications, e.g. a high colour rendering, might prevent products offering those features from achieving these benchmarks”. This again sounds like the kind of issue that would affect entertainment lighting fixtures, but while the problem is recognised here nothing is then done to allow fixtures which fail in this way but are required for these specialist applications.
Finally, there is the comment in the Explanatory Memorandum document that the 82,000 lumen upper limit for light sources covered by these regulations is to “exclude very powerful lamps, e.g. sports lighting, theatre-, stage- and studio-lighting”. However as noted, that light output level is far above the majority of fixtures used for film and theatre lighting. And this is merely an explanation, rather than being an actual part of the new regulation.
It is worth noting that the Directive which enables all of these Eco regulations (2009/125) includes in its Article 15 that the implementing measures should cause “no significant negative impact on the functionality of the product, from the perspective of the user” and that “there be no significant impact on consumers as regards the affordability and the life cycle cost of the product.” In particular it is not yet established whether these rules have since been updated or superseded:
The Association of Lighting Directors, (ALD), have taken the stance that a clearly worded categorical exemption that recognises the specialist nature of the equipment itself and the way the equipment is used in entertainment applications is absolutely required.
Film and TV should be taking the same stance requesting a realistic runway that would allow the core technology and then luminaire manufactures sufficient time to develop tools that supported the overall ECO design objective.
Unfortunately, those entertainment lighting manufacturers who have responded are pointing out that for entertainment lighting products, particularly lensed, very particularly, those using additive colour there is no chance of meeting the new requirements by 2020.
This is for a multitude of technical reasons. The optical design of spotlights relies on having a very small, ideally point source around which to design reflectors and lenses and an optical path. High powered LEDs cannot be “clustered together” as tightly as for example a tungsten filament; instead the source has to be made much larger. The greater size (called “étendue”) leads to higher waste and so lower efficiency.
Trying to achieve this with multiple colours for colour mixing source is even harder, particularly because of the need to have extra light output at the extremes of the colour spectrum to compensate for the human eye’s lower photopic sensitivity at extreme colours. The limitations here are the physiology of the eye and the laws of optics and, ultimately, physics, none of which can be changed by regulation. This is compounded by the fact that colours at the extreme end of the visible spectrum, blue and red, tend to be considerable lower efficacy than green chips. By as much as a factor of 4x or 5x. A further complication here comes because the manufacturers of the base LED sources are currently devoting most of their white light LED sources, which are therefore improving more rapidly than coloured LED white light LED sources with traditional mechanical dichroic colour mixing.
Manufacturers also suggest that getting standby power down to the 0.5W target will be extremely difficult while being able to react to DMX.
The ALD’s objective is to have the EU recognise the “special case” from the regulations for the equipment we use, because of the special demands we place on it.
1. New regulations proposed for September 2020 will impose a minimum efficiency of 85 lumens per watt and a maximum standby power of 0.5W on all light sources (lamps or self-contained fixtures) to be sold in the EU.
2. The existing version of these regulations includes an exemption for stage lighting, studio and entertainment lighting. The new regulations do not (though they do include exemptions for video projection, and suggest an exemption for stage lighting that appears to have mis-understood the light levels/power requirements of most theatrical lighting fixtures).
3. No tungsten fixtures meet this requirement. Many LED-based entertainment fixtures do not meet the proposed requirements. After September 2020 no new stocks of such equipment can be supplied to the market in the EU.
4. Manufacturers suggest that the limits of optical design and LED efficiency mean that they will not be able to create certain types of fixtures that do meet the requirements by September 2020. Probably by 2028. This is due to limitations of the core technology and the laws of physics.
5. Nothing in the rules stops you from using existing fixtures. But bulbs can't be supplied to market and once you can’t get new bulbs, existing fixtures become worthless - effectively scrap. It is unknown how long existing stocks of bulbs will remain available.
6. Replacing your existing fixtures might well mean replacing your entire dimming and
control infrastructure. (for theatre and TV installations)
7. All this for power savings that might be relatively small, given the way entertainment lighting is typically used, and will likely be far outweighed by the scrap created and the energy required to manufacture and distribute new fixtures.
8. Important tools from a DOP and lighting designer’s toolkit will be lost within the EU, some forever.
9. This will dramatically affect Film and TV productions and performance venues of all types, including new and existing (long- running, long-standing rep) productions.
10. There are very few precedents for technologies to be banned if they are not unsafe to use.
There’s an extremely well written, well argued, holistic argument here –
There’s a petition here kicked off by the ALD whose membership have done a huge amount to conduct research and raise awareness of this issue.
If enacted, these rules would have a significant impact on production in Europe and significantly limit access to the DoPs range of tools.