We have been made aware that the European Union (EU) is proposing, in its
Eco-design Working Plan 2016-2019, to change the rules that govern the
light sources used in theatrical productions. In effect, they want to
bring the vast majority of quality theatre lights under the same rules
that govern domestic and office and industrial lighting. These new
regulations are intended to start from 1 September 2020 and if implemented
as originally written, would dramatically impact all areas of
entertainment lighting and all who work in this field – lighting creators,
lighting users and lighting manufacturers. The impact on theatrical
production across Europe will be immediate, and overwhelming, and will
affect venues used by amateurs.
The Association of
Lighting Designers has produced a lot of information about this issue. In particular, it has
summarised the effect of the original proposals as follows:
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
The existing version of these regulations includes an exemption for
stage 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).
No tungsten fixtures meet this requirement. Many LED-based
entertainment fixtures do not meet those requirements. After September
2020 no new stocks of such equipment can be supplied to the market in
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.
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.
Replacing your existing fixtures might well mean replacing your entire
dimming and control infrastructure.
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.
Important tools from a lighting designer’s toolkit will be lost within
the EU, some forever.
This will dramatically affect performance venues and productions of all
types and scales, including new and existing (long-running,
long-standing rep) productions.
There are very few precedents for technologies to be banned if they are
not unsafe to use.
We understand that, as a result of discussions between the industry and
the EU DG Energy Department, a new draft of the regulations, including an
exemption for the entertainment industry, has been prepared. On behalf of
DATA, I have written to all of the East Midlands MEPs seeking their
support to ensure that the new regulations, when they come before the
European Parliament, contain the necessary safeguards for theatres and