I realise I’ve been silent on the subject of the EU and entertainment lighting, with no update since last October. There’s no conspiracy theory: just a sense that maybe the world at large was getting a little tired of it all. Those who really wanted to know could come and find out. Everyone else was perhaps happy that it was just being dealt with.
It has been, to a pretty good degree. A lot of work by a lot of people – preparing information, making our case, briefing civil servants in the UK and other countries who would attend the final meeting about the new regulation – paid off. That meeting took place on December 17 last year. The resulting final regulation included, almost word for word, text we’d written, giving us exemptions we’d sought. The vast majority of entertainment lighting sources, old (tungsten), present (tungsten and arc) and new (LED) are safe, at least for the next five years – though ‘safe’ here means from EU legislation not from manufacturers deciding to just stop production, an entirely different problem.
‘Almost word for word’ doesn’t mean ‘exactly word for word’, of course. One tiny change was made: in a section listing some particular light sources requiring special consideration (high-powered white LEDs, specific tungsten lamps, specific fluorescent lamps used by the film industry, among others) the requirement to meet “one or more” of the specifications was changed to a requirement to meet “two or more”. Which many of the sources listed can’t do – an LED can’t also be tungsten, and a tungsten lamp can’t also be fluorescent.
The frustration with EU process is its lack of transparency at times like this. There’s no way of knowing where this change came from; at the end of that long meeting, the text was agreed, with no further opportunity for review. It has to be passed by the European parliament, but the expectation is that it will be waved through.
This potentially leaves an issue for the light sources in this section, particularly LED sources of the brightness you might want for a stadium-scale moving light or a followspot, but which might not meet the required efficiency standard.
Ironically, the practical solution is to keep using less-efficient (but exempt) arc sources in these applications, which is the opposite of the progress the regulations are meant to encourage – progress that entertainment lighting is achieving at a rapid pace, especially on new shows where rigs are specified from scratch.
The EU’s energy team has suggested it recognises the problem (it also welcomed entertainment lighting to the ecodesign community at a post-meeting event – hopefully, a good sign for the future). The entertainment lighting team driving the industry’s response – made up of the big lighting manufacturers from across Europe – is working on revised wording to deal with this, but that will have to be submitted as a separate amendment to the regulations.
So even though you haven’t heard much, this is still ongoing. The next update will be when there’s something new to report, which may not be for a while.
Rob Halliday is a lighting designer and programmer. Read more of his columns at: thestage.co.uk/author/Rob-Halliday