Update 12: 4th August 2020

by Rob Halliday

Remember when protecting the light bulbs we love from the EU regulators felt like the most pressing thing in the world....?

How times change!

However, even as Coronavirus has taken over everyone’s attention, work has been continuing behind the scenes on the EU’s new Ecodesign regulation to ensure that it does not impact stage lighting, so that we’re free to continue to use the lighting tools we love whenever we get to do lighting again!

To provide a quick summary of what happened and where we currently stand:

  • In late 2017, the ALD became aware that new ‘Ecodesign’ regulations proposed by the EU to start from September 2020 would dramatically impact the tools we use for show lighting. In particular, by tightening up the efficiency requirements light sources would have to meet before being allowed to be sold, and removing an existing exemption for stage lighting applications, many of the light sources we love - tungsten, arc and LED - would potentially become unavailable.

  • At the start of 2018 the ALD launched the ‘Save Stage Lighting’ campaign to bring attention to the issue. The campaign, which included projecting Save Stage Lighting on key arts venues across Europe, attracted widespread attention across the live entertainment community, through the national press and media (with ALD members appearing on television and radio), with MP and MEPs submitting objections and an on-line petition attracting over 84,000 signatures.

  • The ALD submitted a response to the EU outlining the issues, and produced a document for its members explaining the issues.

  • The ALD led several meetings with the UK Government’s Department of Business, Energy and Industrial Strategy (BEIS), the department responsible for these regulations in the UK.

  • The ALD achieved support from leading theatre producers and the Society of London Theatre, and worked with other trade associations and manufacturers from across Europe to raise these issues with the EU via Pearle, the European theatre producers' organisation in Brussels.  As a result a group from entertainment lighting was invited to meet with the EU team in May 2018, and was asked by the EU to produce a technically based exemption for stage lighting.

  • This work was duly carried out, and was largely accepted by the EU and incorporated into the final draft of the new regulation.

  • This meant that most of the light sources we use for show lighting (including most tungsten light sources, with the exception of MR16-style lamps, arc sources and white and colour-mixing LED fixtures) were exempt from the regulations and so could continue to be sold. At the same time the start date of the new regulation was pushed back from September 2020 to September 2021.

  • At a post-meeting Ecodesign party, the EU team specifically mentioned and welcomed the entertainment lighting community to the Ecodesign community!

  • The final text of the new regulation was published in December 2018. The entertainment community quickly identified that while it largely resolved all of the issues surrounding entertainment lighting a subtle change in wording of one section (annex III point 3(w)), the reasons for which were not really understood, meant that an exemption would not be available for some special-case light sources, including high CRI LED sources, high light output LED sources (as you might use in a long-throw moving light or followspot), and the fluorescent sources still used in the film world

  • This issue was raised with the EU in early 2019. In a direct phone call between the ALD and the EU official in charge of this regulation, the EU agreed that this change did go against the goals of Ecodesign (since it would allow arc sources to continue to be used but would in some cases prevent them from being replaced by more efficient LED sources), and would potentially present a conflict with the goals of the ROHS regulations then being reviewed (since if LED replacements for arc lamps were not allowed, there would be a need to provide an exemption for arc lamps from the ROHS regulations, despite an ambition to stop their use because they contain mercury), and so should be addressed.

  • Work has continued on this since. Entertainment lighting was part of a Zoom meeting with the EU in July 2020 during which this was discussed and entertainment lighting proposed a number of possible solutions.

  • Entertainment lighting has since been given indications that the EU will amend this section in a way that will likely allow the sale of high-powered white LEDs and fluorescent sources.

In other words, by identifying the issue, drawing attention to the issue, engaging with the political process about the issue, providing solutions to the issue and continuing to be involved with ongoing discussions about the issue (and related issues - the ALD is also keeping an eye on the EU’s review of its ROHS regulations), the issue was resolved to the general satisfaction of all who are involved in entertainment lighting.

  • The result is that the tools we need and use and love can generally continue to be supplied - though of course in many cases the issue is becoming that though they can legally be supplied, manufacturers might not continue making then, as is already the case with any number of specialist tungsten bulbs and with M16 style tungsten sources.

That’s what presents the biggest issue now, particularly to smaller venues who may not be able to afford to upgrade to newer equipment (or larger venues who may also not be able to afford such upgrades in a financially difficult post-coronavirus world). Though there is perhaps some hope in the money the government is announcing to support green measures - argue that a new LED lighting system is more efficient than an existing tungsten lighting system, and perhaps some of that money could be channelled that way?

Plus of course there’s the slight lack of clarity about what happens as the UK leaves the EU, though its likely the UK will follow this regulation at least to start with, and that manufacturers will follow the EU regulations even for products sold in the UK rather than creating ‘special’ UK versions of products. We certainly don’t expect the UK to produce stricter regulations than the EU, at least in the near-term.

The ALD continues to be here to offer support and advice to any organisation faced with these issues and trying to find the most efficient, cost effective solutions without sacrificing the quality of light which should be at the heart of everything members of the ALD do.

Click Here for a link to the full EU Ecodesign Regulation

Timeline of the SaveStageLighting Campaign

The previous news and updates have been archived in a document that is available from this link.


Be Part of the Conversation

To continue to bring more voices forward discussing how it will affect both the practice of lighting designers and practicalities and costs that venues will face:
The Save Stage Lighting Campaign can be found:
Twitter:       @SaveLighting 

A list of those companies and individuals who are Standing With Us and supporting the campaign, while the coverage we have received from press and media outlets can be found here.