This presentation will show how the EU ban on incandescent lamps is invalid by the Ecodesign Directive’s own criteria, as it fails to fulfil any of the requirements on functionality, energy savings, economy, health, and the environment (updated version)

1. The EU Lightbulb Ban
RevisedversionApril2015
Friday 24 April 15

2. This presentation will show how the EU ban on incandescent
lamps is invalid by the Ecodesign Directive’s own criteria, as it fails
to fulfill any of the requirements on functionality, energy savings,
economy, health, and the environment.
Friday 24 April 15

3. Contents Page
Lamp Technologies 4
Light Quality 6
Light Colour 13
Function 16
Energy 19
Economy 29
Environment 35
Health 44
EC Documents 60
Effects of Bulb Ban 67
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4. Lamp Technologies
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5. Luminescent LightLuminescent Light
Gas Discharge
(FL tube, CFL, HID)
Solid State Lighting
(LED)
Incandescent LightIncandescent Light
Incandescent Halogen
Electric Light Categories
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6. Light Quality
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7. Incandescent Light
Natural, radiating light
Produced by heating a filament
Luminescent Light
Synthetic light
Produced by complex chemical and technical processes
cbv.ns.ca
“incandescent light is produced by
heating a solid object - the filament
- until it radiates light.
In a sense, this is the way light is
produced by the sun.”
- OSRAM
LED
Diagram: OSRAM
Friday 24 April 15

8. Incandescent light and sunlight are “the two ‘golden standards’ of lighting”
- Global Lighting Association
Incandescent Light
Always top quality, just like sunlight
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9. Incandescent Light
Naturally full-spectrum
Luminescent Light
Not full-spectrum
Complete spectrum with all colours visible Gaps with many wavelengths missing
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10. Full-Spectrum Light
Perfect colour accuracy
Colour Rendering Index 100 = lossless
Non-Full-Spectrum Light
Poorer colour accuracy
CRI only 80-85 = lossy
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11. Incandescent light is warm, clear and radiant
Photo: K2 Design (Houzz.com)
Makes all colours in a room look rich and vibrant, with optimal contrast
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12. Synthetic light is more grey and flat
Often too harsh and bright initially, then increasingly dull and dim as it ages
Kleppinger Design Group (Houzz.com)
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13. Light Colour
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14. Incandescent Light Colour
A glowing tungsten filament radiates a
natural warm white light.
Luminescent Light Colours
A phosphor blend creates the light colour
and light spectrum.
energyblogs.com
The light colour is dynamic and turns slightly
whiter at high wattage or low voltage.
The light color is fixed, ranging from warm-
white to cool-white depending on the
phosphor mix.
Friday 24 April 15

15. Soft, warm, and naturally flattering
Incandescent Light
Makes human skin look glowing and healthy
CFL & LED Light
Makes human skin look pale and dead
Photo: Wikimedia
Soft, warm, and naturally flattering Any imperfections get harshly highlighted
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16. Function
“thereshallbenosignificantnegativeimpactonthe
functionalityoftheproduct,fromtheperspectiveoftheuser”
- The Ecodesign Directive
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17. CFL & LED
Only some are dimmable
Incandescent & Halogen
All are naturally dimmable
Dimming incandescent light makes it warmer and
more candle-like, which is perceived as natural.
An incandescent lamp dimmed 30% will last 4
times longer.
Photos: Kevan Shaw
Dimming synthetic light makes it colder, which is
the opposite of what looks and feels natural.
Dimming saves nothing, only raises price and may
cause flicker or noise. Using a non-dimmable lamp
with a dimmer switch will instantly fry the circuits.
Dimming
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18. Incandescent Bulb
• Full light flow instantly
• Colour rendition 100%
• Temperature tolerant
• Minimal flicker
• Naturally dimmable
• Compatible with all dimmers, timers etc
• Sensitive to vibrations and power spikes
• Gets fairly hot
Halogen Lamp
• Full light flow instantly
• Colour rendition 100%
• Temperature tolerant
• Minimal flicker
• Naturally dimmable
• Compatible with all dimmers, timers etc
• Sensitive to vibrations and power spikes
• Gets very hot
CFL
• Takes time to reach full output...
• Colour rendition 80-85%
• Sensitive to heat & cold
• High frequency flicker (24-100 kHz)
• Very few dimmable (extra expensive)
• Only work with some dimmers
• Sensitive to rapid switching on-off
• Creates more electrosmog
LED
• Full light flow instantly
• Colour rendition 75-85%
• Sensitive to heat & power spikes
• May flicker
• Only some are dimmable
• Only work with some dimmers
• Creates more electrosmog
• Cold to touch
Technical Issues Overview
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19. Energy
“The product shall present significant potential for improvement in
terms of its environmental impact without entailing excessive costs”
- The Ecodesign Directive
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20. ElectricityHome Energy
Light
Incandescent
Home Energy Use
EU-27 total final energy consumption = 1168 Mtoe1
Home energy consumption ≈ 25%1 of EU total
Electricity ≈ 22%1 of home energy (the rest is mostly used for heating or cooling)
Lighting ≈ 12.8%2 of home electricity ≈ 2.8% of home energy
Incandescent lamps ≈ 54%3 of home lighting ≈ 1.5% of home energy
1. EuroStat 2008
2. European Commission, Residential Lighting Consumption and Saving Potential in the Enlarged EU
3. VITO 2007 (p. 69, table 2-11)
Transport
33%
Industry
27%
Services
13%
Households
25%
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21. Heat/Light Ratio
The small difference in light/heat output per watt (for the most efficient lamps of each type)
constitutes the entire basis for the idea of ‘energy saving’ lamps.
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Incandescent Halogen ES CFL LED
40%32%10%8%
60%
68%
90%92%
Heat
Light
CFLs and LEDs produce heat too, though less, and mostly internally.
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22. 0%
20%
40%
60%
80%
100%
Incandescent CFL
‘Wasted’ Heat
Useful Indoor Heat
Light
Heat Replacement Effect
• Indoors during the heating season, however, lamp heat is not wasted, but adds to room heat.
1. Canadian Centre for Householding Technology, Benchmarking of energy savings associated with energy efficient lighting in houses
2. UK Market Transformation Programme, BNXS05: The Heat Replacement Effect 2007
“The [67%] reductions in the lighting energy use [by CFLs during the heating season] are
almost offset by increase in the space heating requirements. The results showed that
83% to 100% of lighting energy consumption could contribute to the internal gains.”1
• Outdoors and during the cooling season, CFLs save a larger portion of their original 67%.
• On average, over the whole year, 60% of the heat from home lamps can turn into useful heat
with CFLs saving only 20%.2
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23. Incandescent Lamps
Optimal Power Factor (1.0)
CFL & LED Lamps
Lower Power Factor (0.4 to 0.9)
Circuits with only heating elements have
optimal power factor (PF), producing a smooth
sine curve.
Circuits with inductive or capacitive elements
have lower power factor, producing a highly
distorted waveform.
Power Quality (Lighting Research Center)
Poor PF can cause RF/EMF pollution,
waste energy, harm the electrical
distribution system, and reduce the life of
lighting systems or other electrical equipment!
Power Factor
Friday 24 April 15

24. EU Power Factor Requirements
For the consumer market, the minimum PF requirements are surprisingly slack:
CFLsCFLs LEDsLEDs
2-4 W PF min 0.4
Under 25 W PF min 0.5 5-24 W PF min 0.5
25 W or over PF min 0.9 25+ W PF min 0.9
New EU Requirements
Power Factor (Sylvania)
Producing CFLs and LEDs with higher Power Factor is possible but more costly, so that option
is often reserved for the professional lamp market due to utility penalties if too low.
“Utilities may impose penalties on customers who do not have
good power factors on their overall buildings.” - Sylvania
Dimmable LEDs tend
to have poorer PF
Friday 24 April 15

25. 0
5
10
15
20
25
30
15W CFL 12W LED
Watts
Volt-amperes
Ballasts (W)
Real Energy Used
As most lamps used at home are under 25 watts, this means the average ‘energy saver’ uses
almost twice the energy (e.g. 25VA instead of 15W!) = lamp energy ratings are incorrect!
CFL Real Power Used
Power Factor (Sylvania)
“While the consumer saves watts with any
of the compact fluorescent alternatives, the
utility must generate nearly the same
amount of VA for the magnetic adapter
unit as for the incandescent lamp.”
- Sylvania
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26. Real Energy Use Tested
Benchmarking of energy savings associated with energy efficient lighting in houses
Measurements (highlighted here) made by the Canadian Centre for Housing Technology confirms the poor
power factor (PF) and higher energy use in volt-amperes (VA) for typical CFLs vs. incandescent lamps.
Friday 24 April 15

27. Jevon’s Paradox
When people believe a product saves energy, they will only buy more products or
leave them on for longer.
“Contemporary economists talk about what they call ‘the rebound effect’.
This occurs when the savings that come from using more energy-efficient
machines are offset to some extent by the increased use of machines.”
The Energy Efficiency Paradox
Viva LasVegas: LEDs and the energy efficiency paradox
“The guy burning one light bulb in his little room (and maybe using the excess heat of his
bulb as heating in winter) damages the environment a whole lot less than the guy on the
other side of the street who decorates his mansion and garden like a casino with LEDs.
There is a lot of room to lower energy consumption without switching to new technology.
Something is awfully wrong with our approach to energy conservation.”
The simplest way to save energy is to simply turn lights off when not in use, or to use dimmers
with one’s incandescent lamps. Information campaigns worked wonders for energy conservation
in the 1970s, so why not try it now when people are even more motivated and aware?
Friday 24 April 15

28. Summary Energy Savings
So, about 20% actual savings (with Heat Replacement Effect included)
minus roughly half (with poor Power Factor included) ≈ 10%
of the 1.5% of home energy used by incandescent lamps
≈ 0.15% of an average EU household’s total energy consumption...
0
25,0
50,0
75,0
100,0
Home energy Savings
...or less if you use more lamps, thinking you save so much
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29. Economy
“There shall be no significant negative impact on consumers in particular
as regards the affordability and the life cycle cost of the product.”
- The Ecodesign Directive
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30. Incandescent Life
Originally 2 500+ hours
After 1924 designed to break after 1 000 hrs
Long Life: up to 10 000 hrs
(U.S. Long Life: 20 000 hrs)
Halogen Life
Halogen bulbs for home use are designed to
last about 2 000 hours
With a PowerDisc an incandescent or halogen lamp can last 100 000 hours!
Life Span
Long Life: up to 10 000 hours
Friday 24 April 15

31. LED Life
Rated life: 15 000 to 50 000 hours, but:
• Only the diodes, not the whole lamp.
• The electronics are very
sensitive to overheating,
e.g. in enclosed fixtures.
• Light produced by current through
a semiconductor, which can malfunction
due to poor materials or power spikes.
CFL Life
Rated life: 5 000 to 15 000 hours, but:
• Easily get overheated
in small / enclosed fixtures.
• Base up burning position can
reduce life down to 25% of rated life.
• Designed to be left on for 3 hours.
On for 1 hour = down to 80% of rated life!
On for only 5 minutes =15% of rated life!
Chen W, Davis R, JiY.,An Investigation of the Effect of Operating Cycles on the Life of CFLs” (1998)
Video where typical on times in various rooms are timed
LED Life Expectancy Depends on Fixture Type and Usage Scenario
The great LED lightbulb rip-off: One in four expensive 'long-life' bulbs doesn't last anything like as long as the makers claim
Do LEDs Have a Dark Side?
LEDs and CFLs which do not expire prematurely will gradually get more and more dim,
making their useful life much shorter than their nominal life.
Friday 24 April 15

32. Approx. Price for Lamps Lasting10 000 Hours
€2
€6-18
€10-30
€2.5
€0.5 10 GLS
≈ €5
1 LongLife
≈€2.5
5 halogen
≈ €10
4 CFLs?
≈ €24-72
1 LED?
≈ €10-30
?
?
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33. • Due to the poor Power Factor of most household
lamps under 25W, the more people use CFLs and LEDs,
the more utilities have to increase electricity prices
to compensate themselves for the losses!
Additional Costs
• Many CFLs and LEDs are subsidised by tax money.
• When using CFLs, you need to have
a mercury spill kit (38 to 370 €) at
hand in case of accidents.
• After use, CFLs and LEDs have to be taken to a recycling
plant for toxic waste which also adds extra costs.
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34. Summary ‘Money Savings’
As CFLs and LEDs often:
• don’t give as much light as claimed
• use more energy than claimed
• don’t last as long as claimed
the markedly higher price does not save the consumer any money!
The only ones making money from the ban are the
Big Lighting corporations!
LEDs are much more profitable than incandescent lamps, and
sales are expected to grow by 30% annually - now that the
main competition, the incandescent bulb, has been banned!
Lighting in Europe alone is a ~17 billion € business!
€
€
Instead of penalizing manufacturers for consumer fraud, the Commission is helping them do it!
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35. Environment
“Health, safety and the environment shall not be adversely affected”
- The Ecodesign Directive
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36. Incandescent Bulb
Made of:
• Glass (bulb)
• Tungsten (filament)
• Molybdenium, copper, iron, nickel (support, wires)
• Aluminium or brass (base)
• Tin & antimon (solder)
• 15% nitrogen, 85% argon (inert gas)
Halogen Lamp
Simple to manufacture
May contain:
• Quartz glass (tube or inner bulb)
• Glass (outer bulb)
• Tungsten (gfilament)
• Molybdenium, copper, iron, nickel (support, wires)
• Aluminium, brass or ceramics (base)
• Bromine or iodine (halogen gas)
General Electric, Osram-Sylvania material safety data sheets, How it’s made (video)
Lamp Materials
Very simple to manufacture
Friday 24 April 15

37. General Electric, Osram-Sylvania, Home Depot, LiteTronics.com, MineralsCoalitionEducation.com
LED
Complex and expensive to manufacture
May contain:
• Glass
• PMMA, PBT el PET (brominated polymer)
• Aluminum (heat sink and housing)
• Nickel plated brass (base)
• Bauxit (glass and adapter)
• Lead (glass and adapter)
• Copper (adapter and wiring)
• Nickel (adapter)
• Zink (adapter; semiconductor)
• Tin (adapter; solder)
• Manganese, barium/aluminum oxide (phosphor)
• Rare earth metals (phosphor)
+ Arsenic, boron, gallium, indium, selenium or
phosphate (chip, depending on colour)
CFL
Complex and risky to manufacture
May contain:
• Glass
• Tungsten (anode & cathode)
• Aluminum, copper, nickel, tin or zink
• Nickel-plated brass (base)
• PBT or PET (bromnated polymer)
• Krypton-85 (gas)
• Mercury (vapour or amalgam)
• Lead oxide
• Lead (solder), in EU after 2006: tin
• Manganese, barium or aluminum oxide (phosphor)
• Rare earth metals (phosphor)
EE Times
Friday 24 April 15

38. CFL Mercury
CFLs and LEDs are not easily disposed of as they classed as toxic waste. Hazardous to humans,
animals and the environment if CFLs end up in land fills, for dumpsters in poor countries, and for
recycling staff.
Waste dump with broken lamps (from documentary Bulb Fiction)
"...recycling doesn’t seem to be very profitable. As a consequence, many people don’t know what to do
with their used lamps, moreover they don’t even know that CFLi’s are containing mercury."
Final Report. Lot 19: Domestic lighting. Study for European Commission, 2009,p. 105.
Recycling of CFLs
Mercury in Fluorescent Lighting
Friday 24 April 15

39. One kg can poison 15 lakes.
CFL Mercury
One teaspoon of mercury is enough to poison a medium size lake!
“In 2007, 353 million CFLs were sold in the EU27. Their content of mercury averaged 4 mg. We
assume that 20% of the lamps were recycled, what still leads to the amount of 1,130 kg.”1
1. Mercury in Fluorescent Lighting
One kg can poison 15 lakes. That makes 16 950 lakes! And this was before the incandescent ban!
Friday 24 April 15

40. The Mercury ‘Justification’
So, how does the Commission justify granting CFLs exemption from the RoHS directive
mandating phaseout of mercury in household products?
It appears by believing and forwarding the vested interest’s propaganda about mercury:
This clever PR argument was created in 1991 from a faulty Danish LCA study using the Danish
percentage of coal in electricity generation - which at that time was the highest in Europe, 95%!2
EU overall coal share was significantly smaller then, and is even smaller today. Many countries use
no coal at all. So this argument is totally invalid.VITO also made (deliberate?) miscalculations in
the preparatory study order to make CFLs appear to release less Hg.3
In order to reduce mercury emissions, regulate coal & gold mining - and ban CFLs!
Not a randomly chosen consumer product that contains no mercury or toxic elements and
uses only 0.15% of home energy.
“Mercury is present in compact fluorescent lamps in such a small amount that during its
lifetime a compact fluorescent lamp (CFL) will have saved more mercury emissions from
electricity production in coal power plants (compared to the mercury emissions related to
the conventional incandescent bulbs’ electricity need) than is contained in the CFL itself.” 1
1. Frequently asked questions about the regulation on ecodesign requirements for non-directional household lamps
2. Gydesen,A. & Maimann, D., Life Cycle Analyses of Integral Compact Fluorescent Lamps versus Incandescent Lamps (1991)
3. Historical survey of the introduction of the ban on incandescent lighting in the European Union, chapter 6
Friday 24 April 15

41. Rare Earth Phosphors
LEDs and CFLs contain rare earth phosphors, the mining of which ruins the environment in Asia.
“Miners scrape off the topsoil and shovel golden-flecked clay into dirt pits, using acids to
extract the rare earths. The acids ultimately wash into streams and rivers, destroying
rice paddies and fish farms and tainting water supplies.” - New York Times
Photo: LiamYoung/Unknown Fields
The dystopian lake filled by the world’s tech lust (BBC)
Earth-Friendly Elements, Mined Destructively (NewYork Times)
Friday 24 April 15

42. 1. Potential Environmental Impacts from the Metals in Incandescent, CFL, and LED Bulbs
2. LED products billed as eco-friendly contain toxic metals, study finds
“The CFLs and LEDs have higher resource depletion and toxicity potentials
than the incandescent bulb due primarily to their high aluminum, copper, gold,
lead, silver, and zinc.
Comparing the bulbs on an equivalent quantity basis with respect to the
expected lifetimes of the bulbs, the CFLs and LEDs have 3–26 and 2–3 times
higher potential impacts than the incandescent bulb, respectively.”
Other Metals
CFLs and LEDs have higher environmental impact than incandescent lamps.1
Coloured LED holiday lights contain high levels of toxic elements, such as arsenic and lead.2
Friday 24 April 15

43. Summary Environment
Life Cycle Analyses are often made by lamp manufacturers themselves, based on very optimistic
projections on light output per watt and nominal life rate for their best lamps under optimal
conditions, and usually excluding:
Taking these things into account will generate very different results.
High lumen CFLs and LEDs may have some use in the commercial and
public sectors, especially outdoors, but are are not a green alternative at
home.
• energy and environmental impact of mining for the raw materials (production phase)
• energy and environmental impact of manufacturing the different parts (production phase)
• transport of the various parts (often from different countries) to the factory for assembly
• transport from the factory in Asia on dirty oil tankers (distribution phase)
• the higher real energy use due to poor Power Factor (operating phase)
• the c. 60% Heat Replacement Effect (operating phase)
• the light loss as the lamp ages (operating phase)
• premature death due to poor quality, overheating, wrong use etc. (operating phase)
• collection and transport after use (scrapping phase)
• recycling of the toxic metals (scrapping phase)
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44. Health
Friday 24 April 15

45. S
Mercury in Production
Hazardous for miners, for the environment, and for workers in manual CFL factories.
Sweat shop in India (screenshot from Austrian documentary Bulb Fiction)
“LargenumbersofChineseworkershavebeenpoisonedbymercury, which forms part of
thecompactfluorescentlightbulbs. Asurgeinforeign demand,set off byaEuropean Union
directivemakingthesebulbscompulsorywithinthreeyears, has also ledto thereopeningof
mercury minesthathaveruinedtheenvironment.”
‘Green’ lightbulbs poison workers (TheTimes)
Friday 24 April 15

46. Using CFLs requires having a mercury spill kit at hand in case of accident. How
many people know this? How many can afford €130-300 for a one-time kit?
Mercury at Home
Mercury vaporises at room temperature (!) and is easily absorbed by the body, where it
can cause severe damage to the central nervous system. Extra big risk for children &
pregnant women!
“Mercury causes nervous system defects in children and impedes fetal development.”
Toxipedia
How many have had their homes contaminated and children exposed since 2009?
Friday 24 April 15

47. U.S. EPA Cleanup Guide
1. Before cleanup
a. Have people and pets leave the room.
b. Air out the room for 5-10 minutes by opening a window or door to the outdoor environment.
c. Shut off the central forced air heating/air-conditioning system, if you have one.
d. Collect materials needed to clean up broken bulb:
• stiff paper or cardboard
• sticky tape
• damp paper towels or disposable wet wipes (for hard surfaces)
• a glass jar with a metal lid
2. During cleanup
a. DO NOT VACUUM. Vacuuming is not recommended unless broken glass remains after all other cleanup
steps have been taken. Vacuuming could spread mercury-containing powder or mercury vapor.
b. Be thorough in collecting broken glass and visible powder.
c. Place cleanup materials in a sealable container.
3. After cleanup
a. Promptly place all bulb debris and cleanup materials outdoors in a trash container or protected area until
materials can be disposed of. Avoid leaving any bulb fragments or cleanup materials indoors.
b. Next, check with your local government about disposal requirements in your area, because some localities
require fluorescent bulbs (broken or unbroken) be taken to a local recycling center. If there is no such
requirement in your area, you can dispose of the materials with your household trash.
c. Continue to air out the room where the bulb was broken and leave the heating/air conditioning system shut off
for several hours.
Friday 24 April 15

48. EU
The European Commission has not issued any warnings or mercury cleanup guidelines!
The ‘new’ EU requirements for labeling mercury content
came 3.5 years after the first stage of the phaseout!
And they are still pitifully small, cryptic and easy to miss!
How many even know that Hg means mercury?
How many know what the number means?
How many know what do do in case of an accident?
How many have an expensive spill kit at home?
How many unsuspecting children and pregnant women
have been exposed to mercury since 2009?
CFLs should be marked with a
skull-&-crossbones warning,
as suggested by environmental
expert Minna Gillberg 2009.
Friday 24 April 15

49. Phosphor
Accidental cuts on the glass of a broken CFL means not only risk of mercury poisoning but can
get very nasty as the phosphor powder stops the blood from coagulating.1
1.The Fluorescent Lighting System Images from: Energy Saver Globe
Friday 24 April 15

50. Flicker
Lamps powered by AC electricity flicker at twice the line voltage rate (50 or 60 Hz).
• Flicker has been shown to have negative effects on health and performance
• Light sensitive epilepsy (one in 4 000 people) can be induced by flicker
• Ménières may be aggravated by flicker
• Migraine can be triggered by visible flicker
Küller, R & Laike,T, The impact of flicker from fluorescent lighting on well-being, performance and physiological arousal (1998)
Health Effects of Artificial Light (SCENIHR, 2008/2012) (Wikipedia summary)
Proper driver design eliminates LED light strobe flicker
Many LED lamps flicker, some visible like a strobe light
CFLs and fluorescent tubes with conventional magnetic drivers
sometimes flicker perceptibly, whereas CFLs and fluorescent
tubes with with electronic high frequency drivers turn on and
off 10 000 to 40 000 times per second.
Incandescent and halogen lamps flicker less and more softly,
as the tungsten filament keeps glowing between AC-pulses.
Friday 24 April 15

51. Glare
The extra concentrated light intensity of clear or directional LEDs can cause harmful point
source glare.
1. ANSES, French Agency for Food, Environmental and Occupational Health & Safety (2010) - Original report (fr) Summary (eng)
“These new lighting systems can produce ‘intensities of light’ up to 1000 times
higher than traditional lighting systems, thus creating a risk of glare.
The strongly directed light they produce, as well as the quality of the light
emitted, can also cause visual discomfort.”
- ANSES
Clear halogen lamps can also be quite glaring, so the random ban of frosted halogen lamps
2009 removed the only high-quality glare-free incandescent alternative!
Friday 24 April 15

52. CFL tubes emit ultraviolet radiation through cracks in the phosphor layer1
which can cause skin cancer and eye damage.
CFL UV Radiation Hazard
“Sustained exposure to ultraviolet light wavelengths from CFLs increases the
risk of two seriously debilitating eye conditions, macular degeneration
and cataracts”2, 3
1.The effects of UV Emission from Compact Fluorescent Light Exposure on Human Dermal Fibroblasts and Keratinocytes InVitro
2. Emissions from compact fluorescent lights (Public Health England, 2008)
3. Eye Disease Resulting From Increased Use of Fluorescent Lighting as a Climate Change Mitigation Strategy (2011)
Friday 24 April 15

53. LED Blue Light Hazard
LED health risks comes from the spikes of short (blue) wavelenghts.
The accumulated effect of low exposure can be as big a risk as short, intense exposure.
Warm white LED spectrum Cool white LED spectrum
ANSES, French Agency for Food, Environmental and Occupational Health & Safety (2010) - Original report (fr) Summary (eng)
“The blue light necessary to obtain white LEDs causes toxic stress to the retina.”
- ANSES
Friday 24 April 15

54. Blue Light Retinal Damage
Further evidence of LED light damaging your eyes
“The present data clearly demonstrated irradiation of the white LED is above 400 nm
and is not within the ultraviolet light region. However, the exposure of eye in LED
illuminated environment was related to the development of photoreceptor loss.”
Friday 24 April 15

55. Groups Especially at Risk
Groups dependent on incandescent light for their health have now been deprived of safe
alternatives and the Commission has not provided any useful alternatives.
ANSES, French Agency for Food, Environmental and Occupational Health & Safety (2010) - Original report (fr) Summary (eng)
Health Effects of Artificial Light (SCENIHR, 2008/2012) (Wikipedia summary)
• Patients with UV sensitive skin conditions (photodermatoses, incl. Bloom &
Rothmund-Thomson syndrome, xeroderma pigmentosum, actinic prurigo, chronic
actinic dermatitis, urticaria solaris, polymorphic light eruption, photophobia)
• Patients with blue light sensitive eye conditions (AMRID, aphakia, pseudo-aphakia
(whose eyes cannot, or can only partially, filter blue light)
• Patients with blue light sensitive skin conditions
• Children (whose eyes cannot yet filter blue light well)
“There are a number of patients (around 250,000 EU citizens; SCENIHR 2008)
that are exceptionally sensitive to UV/blue light exposure. The risk for this group of
patients includes all light sources with significant UV/blue light emissions.”
Friday 24 April 15

56. Blue Light Bio-Disruption
Blue-white light inhibits melatonin even at very low light levels, and can cause problems with
sleep, mood, and metabolism, leading to conditions like obesity, diabetes, or depression.
Red and infrared wavelengths are needed, especially in the evening, in order to stimulate
regenerative processes in the body.
Incandescent light has a larger portion of red and is therefore the best light source at
home at night.
Dimmed incandescent light is even more ideal, as it gets more red and less bright.
Stephen M. Pauley, M.D. - Lighting for the Human Circadian Clock
Too little light in the day, and not enough darkness at night: How our sleep patterns are changing for the worse
Friday 24 April 15

57. General Health & Wellness
Besides being all-important for vision and mood, light is an essential bio-nutrient.
Quality matters!
Banning top quality incandescent & halogen light and mandating CFLs and LEDs
is like banning fresh organic vegetables and allowing only junk food!
Friday 24 April 15

58. EM Emissions & Safety
Most LEDs are made in China/Taiwan by a wider range of small and large companies than for
traditional lamps, which also creates greater quality variations and more electrical safety and
electromagnetic compatibility issues.
1. 4th EMC Market Surveillance Campaign 2011
2. More LED Issues
3. Philips Recalls 99,000 LED Light Bulbs Due to Shock Risk
4. Lighting Science issues recall of 554,000 LED bulbs because of fire hazard
“Dimmable LED lamps contain control electronics that often require
specific measures to achieve acceptable properties to make electrical
devices work together, known as electromagnetic compatibility
(EMC). This is sometimes overlooked by the lamp manufacturers.”
In the electromagnetic compatibility (EMC) surveillance campaign on LED lamps
2011, 168 lamps were tested for electromagnetic emissions (harmonics and
radio frequencies due to poor Power Factor from cheap drivers).
Only 61.5% passed the tests and almost 24% were either not CE marked
or did not carry a compliant CE marking.1
Many batches of LEDs have also been recalled due to electrical safety issues. 2, 3, 4
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59. Summary Health Risks
Potential health risks from:
• Mercury (CFLs)
• Phosphor (CFLs & LEDs)
• UV radiation (CFLs, unfiltered halogen lamps)
• Blue light hazard (LEDs, especially when the die is visible)
• Blue light hormone disruption (LED lamps & OLED screens)
• Flicker (some LEDs and CFLs with magnetic ballasts)
• Harmful glare (clear & directional LEDs, clear & directional halogen lamps)
• Electrical safety issues (some LEDs)
Even though SCENIHR,The European Commission and ELC have done their best to downplay
them, these health risks cannot be ignored.
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60. EC Documents
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61. The Ecodesign Directive
The Ecodesign Directive (2009) includes the following criteria:
2. The criteria referred to in paragraph 1 are as follows:
(a) the product shall represent a significant volume of sales and trade, indicatively more than 200 000 units a year (...)
(b) the product shall, considering the quantities placed on the market and/or put into service, have a significant
environmental impact within the Community (...)
(c) the product shall present significant potential for improvement in terms of its environmental impact without entailing
excessive costs, taking into account in particular:
(i) the absence of other relevant Community legislation or failure of market forces to address the issue properly;
(ii) a wide disparity in the environmental performance of products available on the market with equivalent functionality.
5. Implementing measures shall meet all the following criteria:
(a) there shall be no significant negative impact on the functionality of the product, from the perspective of the user;
(b) health, safety and the environment shall not be adversely affected;
(c) there shall be no significant negative impact on consumers in particular as regards the affordability and the life cycle
cost of the product.
(d) there shall be no significant negative impact on industry’s competitiveness;
(e) in principle, the setting of an ecodesign requirement shall not have the consequence of imposing proprietary technology
on manufacturers; and
(f) no excessive administrative burden shall be imposed on manufacturers.
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62. The BiasedVITO Study
Dutch consultantsVITO’s technical study, ordered by the Commission to prepare for the
regulation on household lamps, appears to have been designed to produce a specific result,
already determined in advance and therefore highly flawed on too many counts to list. Here are
but a few examples:
• Lumping together all CFL models into one group (bare, covered, dimmable, outdoor, daylight, etc.,
despite their widely varying quality levels, efficacies, applications, energy ratings, and rated life) and
using the optimistic nominal values of the most efficient CFL type to represent the whole group!
• Putting clear and frosted GLS in separate classes, despite the difference in output being virtually non-
existent and all other things the same.
• Miscalculations of Hg emissions!
• Overly optimistic estimations of CFL recycling rates, 20% in all of EU, despite lack of recycling
schemes.
• Not counting the mining process for the mercury and phosphors in CFLs (stating a ‘lack of info’).
• Making distribution impact estimates on the assumption that all lamps are produced in Europe, while
fully aware (= mentioning!) that most CFLs are produced in Asia!
• Downplaying health effects and technical issues and giving incorrect information.
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63. The Misleading Technical Briefing
As basis for the lightbulb ban, a grossly misleading summary was presented to the MEPs.
“Lighting may represent up to a fifth of a household's electricity consumption.”
The correct number according to the Commission is a mean of 12.8% (or 2.8.% of total household energy)
“There is a four to five-fold difference between the energy consumption of the least efficient and the most
efficient lighting technologies available on the market.”
Only in theory. In reality, with Heat Replacement Effect and Power Factor, only a few watts, or about 10%.
“This means that upgrading the lamps could reduce a household's total electricity consumption by up to
10-15% (...)”
But lighting is only 12.8% of home electricity, and only 54% of those were incandescent in 2007! This makes 6.9%
of home electricity. Saving 10% of that is 0.69%! (And synthetic light is always a downgrade.)
“In the context of the commitment of European leaders to reduce primary energy consumption by 20%
compared to projections for 2020, the Spring European Council 2007 invited the Commission to ‘rapidly
submit proposals to enable increased energy efficiency requirements (…) on incandescent lamps and other
forms of lighting in private households by 2009’.”
Note how the initial “fifth” is made to seem like the 2020 goal by misrepresenting the numbers.
But home energy is only 25% of EU total energy consumption
Home electricity is only 22% of a household’s total energy consumption = 5.5% of EU total energy
Lighting is only 12.8% of home electricity = 2.8% of household energy = 0.7% of EU total energy
of which only was 54% incandescent before the ban = 0.38%, of which saving 10% = 0.03%!
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64. The Halogen Lie
While the halogen phaseout scheme was given on the EU page for lighting professionals...
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65. The Halogen Lie
...EU private consumers were led to believe that halogen energy savers would still remain
available indefinitely for those who want or need an incandescent alternative:
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66. The Halogen Lie
• But B-class incandescent
(halogen) bulbs do not exist! They
were produced by Philips only for
a brief period around the initiation
of the ban and then removed
from the market.
• C-class halogen energy savers
will be banned from 2018
(original plan 2016).
So, these assurances were just
lies and European consumers
will have no quality lamps
left to buy!
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67. Effects of Bulb Ban
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68. Consumer Confusion
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69. Incandescent Simplicity
When buying a new light bulb, wattage used
to be all you needed to know.
Puzzling Lamp Jungle
Now you have to learn to decipher over a
dozen new technical parameters.
Without professional help, chances of getting the
right bulb for one’s lighting needs are slim.
All lamps were cheap, top quality and had perfect
functionality, so purchase was easy.
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70. Not Interchangeable
Same top light qualitySame top light quality Lower quality, different functionalityLower quality, different functionality
Same mediocre light qualitySame mediocre light quality
CFLs can only replace or
be replaced by LEDs
Incandescent bulbs can not be replaced
by CFLs or LEDs
Same top light qualitySame top light quality
Clear incandescent bulbs
can only be replaced by
clear halogen bulbs
Frosted incandescent
bulbs can only be replaced
by frosted halogen bulbs
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71. • Highly Sensitive People
15-20% of the population are highly sensitive (HSP).
According to informal polls, a majority seem to prefer
and feel best in incandescent light (or candle light) and
strongly dislike fluorescent tubes, CFLs and LEDs.
• Seniors
Quantity: Lighting needs increase dramatically with age. Some may
actually need a 150 watt halogen torchiere to light up the room
instead of several dull CFLs.
Quality: Distinguishing colours gets harder with age. CFLs and
LEDs are therefore unsuitable due to the suboptimal colour
rendition.
Glare: Sensitivity to glare increases with age. Frosted incandescent
and halogen lamps are the only non-glaring, good quality option.
Deprived Consumer Groups
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72. • Art & Colour Professionals
Many professionals, e.g. artists, conservator-restorers, dental technicians, decorators,
designers, fashion designers, florists, makeup artists, interior designers, lighting designers,
photographers, cosmetic surgeons, etc., are often highly dependent on perfect colour
rendition (= incandescent/halogen light).
Capriciously robbing all these groups of important tools needed in their respective professions
can hardly be considered acceptable in a free market.
Deprived Professional Groups
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73. As it is not, and never will be, technically possible to
produce the same warm and radiating light by
synthetic techniques, banning incandescent light is
the same as banning beauty, comfort and the
ability to create a cosy, relaxing, and attractive
home environment. It also affects high-end shops,
restaurants, hotels, galleries, museums, etc.
Banning Beauty
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74. Conclusion
1.As the Ecodesign Directive clearly states that implementing measures shall meet
ALL the criteria, the incandescent ban and impending halogen ban 2018 is thereby
invalid and must be revoked with no delay.
2. CFLs containing mercury vapour should be immediately banned from sale for
the private consumer market, in accordance with the RoHS Directive and the
Minamata Convention.
Those who have lobbied for and forced this toxic technology on
an unsuspecting public, and also contributed to serious health- &
environmental problems in Asia, should be held accountable.
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