COP4

Both the African region and the European Union submitted draft amendments to Annex A of the Convention text which apply to mercury-added lighting. These proposals were discussed at COP 4.2 in March 2022. The African Amendment Proposal calls for the phase-out of manufacture, import and export of virtually all fluorescent lighting by the end of 2025. The European Amendment Proposal calls for the phase-out of manufacture, import, export of halophosphate linear fluorescent lamps by the end of 2023.

The 36 countries/Parties to the Minamata Convention representing the African region submitted a proposal to the Secretariat of the Minamata Convention that included a proposal to modify the lighting product exemptions in Annex A. Due to the toxic mercury contained in every fluorescent lamp and widespread availability of cost-effective, more energy-efficient LED alternatives which contain no mercury, the proposal calls on the Minamata Convention to phase-out virtually all fluorescent lighting by the end of 2025. 

Please click here to view a copy of the African Amendment Proposal submitted to the Minamata Convention on 30 April 2021. The proposed amendments related to lighting are indicated on the first part of the submittal. 

The proposed amendment covers the most common types of fluorescent lamps, including both compact fluorescent and linear fluorescent lamps. The African region proposed inserting three new rows into the Part I table of Annex A to the Convention which correspond to the same three categories of fluorescent lamps already identified in the Part I table, but which currently only limit the amount of mercury per lamp.  

The proposal recommends inserting three rows of text into the table that will phase-out the manufacture, import and export: (1) all integrally ballasted CFLs (CFL.i) by the end of 2024; (2) all linear fluorescent lamps (LFL) by the end of 2025; and (3) all cold-cathode and external-electrode fluorescent lamps (CCFL and EEFL) by the end of 2024. Below is the table from the proposed African lighting amendment: 

As lighting markets in wealthy countries shift to clean LED lighting, less-regulated markets may experience “environmental dumping” of old fluorescent technologies. Many of the OECD countries have passed or are considering policies that will ban the sale of mercury-laden, inefficient lighting products in their domestic markets, however they would still allow domestic manufacture and export to less developed and emerging markets. This puts the public and environmental health of those countries at risk. The proposed amendments by the African region would ensure a global phase-out of fluorescent lighting, eliminating mercury at the source by ending the manufacture, export and import of mercury-based lighting products. 

Additionally, the cumulative (2025-2050) global benefits of the African Lighting Amendment would be significant: 

• Eliminate 232 tonnes of mercury pollution from the environment, both from the light bulbs themselves and from avoided mercury emissions from coal-fired power plants; 
• Reduce global electricity use by 3%; 
• Avoid 3.5 gigatonnes of CO2 emissions cumulatively between 2025-2050; equivalent to removing all passenger cars globally from the road for a whole year; and 
• Save US$1 trillion on electricity bills. 

As a supplement to the African Amendment Proposal on Lighting, the Region included 9 pages of justification for the proposal (called “Annex II” in the African Region’s Submission to the Secretariat). That document identifies numerous policy initiatives across the African Continent that are working to improve the efficiency of lighting and appliances, and many governments are already moving to phase-out CFLs and LFLs through energy-efficiency policy measures.  There are twenty-one countries in UNIDO’s Energy Efficient Lighting and Appliances project developing and adopting harmonised lighting performance standards which will phase-out CFLs and LFLs through the minimum efficacy (lumen/Watt) requirement – fluorescent lamps do not meet the minimum requirement, and are therefore to be phased-out in the region. . One of Africa’s largest economic trading blocks – the Southern African Development Community – recently adopted SADC HT-109:2021, which is poised to phase out CFLs and LFLs in the region over the next few years. 

Additionally, South Africa is working to phase out CFL and transition to LED, while the six nations of the East African Community are adopting regional lighting regulations that will phase-out all fluorescent lamps, moving these markets to mercury-free LED. Burkina Faso, Gabon and many other countries have strategies to support energy-efficiency measures in their national energy policies.

On 30 April 2021, the European Union (EU) submitted a proposal to the Minamata Convention on Mercury including several suggested revisions to the exemptions in Annexes A and B. One of the amendments proposed by the EU focuses on lighting. The proposed European Union Lighting Amendment aims to phase-out of manufacture, import, export of halophosphate linear fluorescent lamps in 2023.

Through draft and existing regulations, the European Commission is currently phasing-out all general purpose fluorescent lighting. In October 2019, the EU adopted an Ecodesign regulation (EU No 2019/2020) that phases-out approximately half of the fluorescent lamps – including T8 and T12 linear fluorescent and compact fluorescent lamps. In June 2021, the EU proposed to phase-out all the remaining fluorescent lamps under a draft revision to the Restriction of Hazardous Substances (RoHS) Directive. While these domestic regulations will create lower-cost, healthier and better lighting for people living in the EU, they would still allow factories in the EU to manufacture and export fluorescent lamps for sale in other markets around the world. 

The EU lighting amendment proposal does not propose to phase out the same products in the Ecodesign regulation or those currently proposed under the RoHS Directive. Rather, the proposal from the EU only covers halophosphate lamps, which can immediately be replaced by mercury-containing tri-band phosphor fluorescent lamps in the same sockets, thus mercury would continue to persist in lighting markets.