Refurbishing Europe’s Fluorescent Lamp Manufacturing Facilities
The EU-27 are currently in the process of phasing-out domestic consumption of fluorescent lighting. There are two regulations – one final and one draft – that will eliminate fluorescent lighting by 2023:
- Ecodesign Directive: Commission Regulation (EU) 2019/2020.
- Restriction of Hazardous Substances (RoHS) Directive: RoHS is completing its Parliamentary and Council scrutiny period in the coming few months.
Despite ambitious domestic policy to ban inefficient, mercury-containing lighting products, these internal market policy decisions stand in stark contrast to the position the EU-27 took in their proposal to amend lighting products in the Minamata Convention on Mercury. Through the Convention, the EU only proposed to phase-out halophosphate fluorescent lamps – a technology the EU banned in 2011. It is important to note that the Ecodesign and RoHS Directive regulations only apply to the EU’s internal market and thus do not affect exports; however a ban to these same products under Minamata would eliminate exports of those fluorescent lamps.
Europe has two manufacturing facilities for fluorescent lamps which are currently operational – one in Poland and one in Germany. The fluorescent production lines at these lighting factories are limited because the product they produce is no longer fit for purpose. EU domestic market for fluorescents will be gone in 2023 and regional export markets to the European Economic Area, the United States and other countries is also being phased out by separate legislation.
To be viable, converting the facilities in Poland and Germany from T8 and T5 linear fluorescent lamps to T8 and T5 LED retrofit tubes will require EU government investment. This study demonstrates that the fluorescent export market from these countries is already in decline and projected to reach zero around 2025. However, through the EU Taxonomy Fund, there is potential to invest in these facilities and create a long-term, domestic supply of high-quality LED tubes in Europe, produced in Poland and Germany.
This report highlights this opportunity for a Taxonomy Fund investment in EU manufacturing of energy- efficient, high-value-add LED tube manufacturing, which will result in significant employment and climate benefits.
Market Transformation Toolkit
Governments and people no longer need to tolerate toxic, fluorescent lights. Ten years ago, fluorescents were promoted as an energy-efficient alternative to incandescent and halogen light bulbs, and the risks associated with mercury in fluorescents were tolerated as a necessary trade-off. Today, thanks to major advances in light-emitting diode (LED) technology, LED lamps are a safer, mercury-free, cost-effective alternative that can replace fluorescent lamps in virtually all applications.
This toolkit is a resource for governments aiming to accelerate the transition to LED lighting in their national market. As OECD governments ban toxic fluorescent lighting due to the mercury content, government officials must protect their lighting markets from becoming dumping grounds for these banned products. In un- and under-regulated markets, fluorescents are still one of the market leaders. This toolkit contains a wide range of suggested interventions including draft policies, initiatives and programs that governments can launch that will push, pull and support a sustained transition toward energy-efficient LED lighting.
The resources offered in this toolkit are organized to follow the United for Efficiency (U4E) integrated policy approach but have been adapted and tailored to focus on lighting markets. The market interventions are grouped into five thematic areas:
Policy interventions that provide a ‘market push’ that protects national markets from being flooded with substandard, poor quality products. Often referred to as Minimum Energy Performance Standards or MEPS, these market regulations encompass a collection of requirements that determine which products can be sold and which are blocked. Standards are the cornerstone of a transition to energy-efficient lighting.
Market interventions that provide a ‘market pull’ mechanism, either through informing consumers, incentivizing change in the supply chain or similar actions. Examples of supporting policies include product labelling schemes, endorsement labels, procurement specifications and information/communication campaigns to inform consumers and encourage switching to LED lighting.
Affordability identifies solutions for any first-cost challenges that may exist with LED lighting, including fiscal instruments, incentives, import duty relief, Energy Service Companies and revolving green funds. It also considers incentive mechanisms that overcome incremental costs such as electric utility on-bill financing, trade-in schemes and pay-as-you-save schemes which rely on shared energy savings.
As markets transition and policies and programs are implemented, it becomes increasingly important to ensure suppliers and retailers are following the rules, maintaining a level playing field. This includes market monitoring, verification of performance declarations and enforcement actions taken against non-compliant suppliers. Compliance is strengthened through regional cooperation and sharing of information and skills between countries and across regions.
At the end of life, lighting products should be disposed of responsibly, taking into consideration issues of e-waste and any hazardous chemicals. All fluorescent lamps contain mercury which is one of the top 10 chemicals of major public health concern. Looking holistically, governments can adopt measures in line with global best practice in order to minimize future impacts, establishing a legal framework and program to ensure environmentally sound, end-of-life treatment of all lighting products.
Clean Lighting Supports 8 Sustainable Development Goals
Accelerating the transition to clean and efficient lighting through the Minamata Convention will achieve a better and more sustainable future for all. Mercury is a highly toxic chemical found in the environment. Once released, it cycles back and forth between the air and soil, all the while changing chemical forms. Commonly used in offices, homes and public spaces, a fluorescent bulb contains 3 to 30 mg of mercury, posing a threat to people and the planet.
Launched in 2013 with the goal to “Make Mercury History” by eliminating the use of mercury in products and processes worldwide, the Minamata Convention on Mercury, which entered into force in 2017 following ratification by 50 countries still includes exemptions for mercury-based fluorescent lighting products citing insufficient cost-effective alternatives across global markets. Recent advancements in light-emitting diode (LED) technology have enabled LED lights to become a safe and cost-effective alternative to fluorescent lighting, rendering the exemption unnecessary.
Recognising the opportunity to transition lighting markets to LED lighting, capture the benefits of global equity and sustainable development, thirty-six African countries submitted a proposed Amendment to the Convention calling for the phase-out of mercury-containing fluorescent lighting by 2025. This proposal to accelerate the transition to LED lighting will improve the well-being of people and the planet by supporting objectives and achievement of eight Sustainable Development Goals (SDGs):
SDG 3: Good Health and Being
Ensure healthy lives and promote well-being for all at all ages
Mercury exposure can affect the nervous, digestive and immune systems, as well as the lungs, kidneys, skin and eyes. Exposure to mercury – even small amounts – can bring health risks especially to developing fetuses, infants and children. The biggest risk to our health is when a mercury-bulb breaks. If the mercury is not immediately contained or cleaned up, it can become an invisible, odorless gas that people inhale, with 80% of inhaled mercury being absorbed by the body. Fluorescent lamp breakage is most common at the end of life where the majority of fluorescent bulbs are discarded into general waste streams. LED lamps represent a safer and clean alternative to fluorescent lamps that remove any risk of exposure to mercury, a highly toxic substance. By phasing out fluorescent lighting, the Minamata Convention will contribute to the objectives of SDG 3 on Health, and in particular SDG 3.9 which seeks to substantially reduce the number of deaths and illnesses from hazardous chemicals and air, water and soil pollution and contamination.
SDG 7: Affordable and Clean Energy
Ensure access to affordable, reliable, sustainable and modern energy for all
Compared to today’s LED lighting, fluorescent lighting is an old technology that consumes twice as much energy to produce the same amount of light. Thus, replacing fluorescent lights with LED alternatives is fully aligned with the objectives of SDG7 – and in particular, SDG 7.3 to double the global rate of improvement in energy efficiency. Because LEDs are more efficient and last longer than fluorescent lights, they lower energy bills for consumers and business, and can support increased energy access under SDG 7.1 on universal access to affordable, reliable and modern energy services.
The payback period associated with the LED replacement of fluorescent lights is in most cases less than a year making them a highly cost-effective alternative to toxic fluorescent lamps. In some countries, including the United States and South Africa, LEDs are approximately 50% less expensive to own and operate than a CFL. Even in Uganda, where only 60% of the urban population has access to electricity, a market analysis found that the life-cycle cost of owning and using a CFL is almost double that of using an equivalent LED bulb. At the international level, the Clean Lighting Coalition (CLiC) estimates that if the African Lighting Amendment is adopted, it would reduce global electricity use by approximately 3%.
SDG 8: Decent work and economic growth
Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all
The World Health Organization classifies mercury as one of the top ten chemicals of major public health concern. Mercury exposure from fluorescents is possible at every stage of their life cycle, including manufacturing, transportation, installation, use and finally disposal. Workers involved in fluorescent light manufacturing and recycling can be exposed to emissions or spills from the treatment, dosing of lamps at the factory and from broken lamps and waste. A health study that looked at a fluorescent lamp recycling plant in Madison, Wisconsin, found that workers exhibited symptoms of mercury exposure. When installing, using and removing lamps, there is a risk of breakage and only a small fraction of the fluorescent lamps are recovered and recycled at the end of life. The vast majority are simply disposed of with the general waste where the mercury escapes from the broken lamp and is released to the environment.
Supporting the phase-out fluorescent lighting would reduce occupational exposure to mercury and help to achieve the objectives of SDG 8.8, which aims to protect labour rights and promote safe and secure working environments of all workers, including migrant workers, particularly women migrants, and those in precarious employment.
SDG 10: Reduced Inequalities
Reduced Inequality within and among countries
In addition to being toxic, fluorescent lighting is an old, inefficient light source which is no longer competitive in today’s market. This has been recognized by wealthy nations and countries, for example the 27 members of the European Union, who are now taking steps to phase out fluorescent lamps. As that is happening suppliers of fluorescent lamps are looking for new markets to sell their products, raising concerns about equity. As wealthy countries and developed economies lead the transition to LEDs, the rest of the world – developing countries and emerging markets –must not be treated as a dumping ground for outdated, mercury-laden fluorescents that are banned in most of the OECD region.
SDG 10.4 calls for countries to adopt policies, including social protection policies, that will progressively achieve greater equality, and SDG 10.5 calls for a framework to implement these policies. Adopting the African Lighting Amendment to the Minamata Convention supports the achievement of these goals, as it would ban trade in fluorescent lights, prevent emerging economies from becoming a dumping ground for toxic, inefficient lighting. Through the adoption of this Amendment, the Parties to the Convention will be sending a signal to the global lighting market that it is time to reduce technology and product inequalities, and promote access to safe, efficient, clean LED lighting for all, regardless sex, age, disability, race, class, ethnicity or religion.
SDG 11: Sustainable Cities and Communities
Make cities and human settlements inclusive, safe, resilient and sustainable
The collection of mercury lamps at the end of life including waste separation and collection, transport, disposal, and mercury recovery remains a main concern around the world. Even in countries where there are systems in place for electrical and electronic waste management, recycling is still limited. A 2016 report by the Danish Environment Protection Agency found that Denmark, which has one of the highest collection rates in the EU, had achieved an overall bulb collection rate of only 36%. In the United States, recycling rates have been reported at 29% for industry recycled fluorescent lamps and CFLs, and at only 2% for consumers. In Africa, e-waste that is collected and properly recycled (including lighting products) was at 4% in Southern Africa, 1.3% in Eastern Africa and close to 0% in other regions.
Mercury leakage into the environment contaminates the air and water around the cities and settlements where we live. Replacing fluorescent lights with LEDs will eliminate the risks associated with managing hazardous wastes, and contribute to SDG 11.6; to reduce the adverse per capita environmental impact of cities, including by paying special attention to air quality and municipal and other waste management.
SDG 12: Responsible Consumption & Production
Ensure sustainable consumption and production patterns
The Minamata Convention requires Environmentally Sound Management (ESM) of products containing mercury directly contributing to the achievement of SDG 12. ESM is one of the multilateral frameworks supporting SDG 12.4; to achieve the environmentally sound management of chemicals and all wastes throughout their life cycle, […] and significantly reduce their release to air, water and soil in order to minimize their adverse impacts on human health and the environment. The UN Environment Programme established a Partnership Area under the Convention, as a means to support the development of such an EMS to minimise and eliminate unintentional mercury releases to the environment from waste containing mercury through a Life Cycle Management approach.
Through the phase-out of fluorescent lighting, developing countries will benefit from developing ESMs to deal with end-of-life management more effectively in order to reduce mercury releases. Moving forward, transitioning to LED lighting will eliminate the need for ESM of mercury-containing (fluorescent) lamps.
SDG 13: Climate Action
Take urgent action to combat climate change and its impacts
LEDs offer an ideal mechanism – reduced mercury and CO2 emissions- to help achieve SDG 13 and combat climate change. CLASP estimates that if the African Lighting Amendment is adopted, the world would save up to 3.5 gigatonnes of CO2 emissions cumulatively between 2025 and 2050 mitigating the adverse impacts of fluorescent lighting on the climate. Phasing out fluorescent lights by 2025 would also result in removing 232 tonnes (cumulative 2025-2050) of mercury pollution in the environment from the bulbs themselves and from avoided burning of coal in power stations. Phasing out fluorescents, through the Convention would provide Parties with a global framework for eliminating mercury-laden lighting and contribute to SDG 13.2; to integrate climate change measures into national policies.
SDG 14: Life Below Water
By 2025, prevent and significantly reduce marine pollution of all kinds, in particular from land-based activities, including marine debris and nutrient pollution
Along with other anthropogenic product and processes containing mercury, mercury-based lighting contributes to the contamination of global waters and ecosystems. Mercury released from incorrect disposal of fluorescent lamps and atmospheric releases from coal combustion for fluorescent lamps contribute to mercury deposits into water. Similarly, mercury-contaminated soils permeate into ground water, in turn polluting surface water. Once in the water, mercury can be transported long-distances and bacteria processes transform it into methylmercury – the most-toxic form of mercury to people. Methylmercury bioaccumulates and biomagnifies in the food chain, in particular in predatory fish, to the point where consumption advisories have been issued against eating shark, swordfish, bigeye tuna and king mackerel, especially by pregnant women. Arctic countries are particularly exposed to transboundary mercury pollution which presents a threat to the ecosystem and vulnerable indigenous communities, who rely on fish as the main source of food and for their livelihood. Replacing fluorescent lights with LEDs would therefore contribute to preventing water contamination, help achieve the objectives of SDG 14.1; to prevent and significantly reduce marine pollution of all kinds.