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Update on Lighting Regulations

Report from Chris Newall & Andrew Whadcoat, The Questors Theatre.

We attended a meeting arranged by the Association of Light Designers (ALD) on 21 November 2018 to provide an update on the EU lighting regulations and their future impact on The Questors.

The draft EU lighting regulations as published in the Spring of 2018 would have left our theatre in a situation where by 2020 we would no longer be able to source spare lamps for the majority of The Questors theatre lights in service – and the current versions of LED lighting that we have started to source do not comply with the proposed regulations either. We would be able to continue to use existing lamps and stock but be unable to procure any more.

We were provided with some useful context and background, the outlook and what we need to focus on long term. The main points we picked up were…

1. The ALD had worked in a coalition with a number of other European bodies to successfully lobby the EU since the Spring of 2018.
2. The EU lighting regulations review is led by their Energy Commission which has little understanding of arts and culture needs – their focus is on architectural lighting, industrial, commercial and domestic – the main users of lighting equipment.
3. Stage and Studio had been exempt from previous regulations so those industries had not paid attention to the EU and what was happening – the draft regulations in the Spring were a surprise.
4. The meeting with the EU in May – 5 people had been allowed in to present – the strategy was to tell a story that the EU Energy Commission could understand – by the time it got to the last presenter – the technical detail with a proposed way forward – the EU began to understand the problem
5. As a result in the latest draft of the regulations the majority of lamps we use are now to be exempt. However it likely that R7 (flood lights) and MR16 (birdies) and some other specialist lamps will not be exempt.
6. There are some remaining, but lesser, issues explained in the detailed ALD response document – some of these potentially have work arounds.
7. However, although many tungsten lamps we use have now been exempted, we should still be concerned about longevity of supply as…
a. These lamps are made on production lines that make domestic and commercial lamps most of the time, switching to specialist lamps for short runs. It is therefore likely that as commercial and domestic production will be banned, the cost of relatively small specialist production runs will rise
b. The EU normally review these regulations every 5 years so we can expect that the next review in 5 years will not be as generous towards our industry – a key part of the ALD argument was 2 years is not enough for us to remove dependency on tungsten lamp supply. Whether the UK is subject to the next generation of regulations is probably not material as manufacture is non UK anyway

The strong message coming through at the end of the meeting was that we need to plan ahead to remove our dependency on the supply of tungsten lamps.

The full text of the ALD Response to the Review of Ecodesign Requirements for Lighting Products with Regards to Entertainment Lighting is attached and can also be found by following the links on the ALD website

Chris Newall, Andrew Whadcoat