Derby Arts and Theatre Association DATA
Proposed New EU Eco Design and Eco Labelling Regulations

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:

  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. 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 those 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.

  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.

  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 lighting designer’s toolkit will be lost within the EU, some forever.

  9. This will dramatically affect performance venues and productions of all types and scales, 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.

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 concert halls.