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Clarifications on Lighting Europe’s Comments to the RoHS Committee

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Europe is considering whether to extend the exemptions granted to certain products listed in Directive 2011/65/EU of the European Parliament and of the Council of 8 June 2011 on the restriction of the use of certain hazardous substances (RoHS) in electrical and electronic equipment. Fluorescent lighting is one of the product groups exempted from RoHS, even though mercury-free substitutes for this product are widely available in the lighting market.

The Swedish Energy Agency and CLASP have worked together to produce a series of market and technology studies that consider whether the exemptions for fluorescent lighting should be continued or retired. The first report was issued in October 2019, followed by an update to that report in December 2019 and later a review of the RoHS criteria relative to fluorescent lamps in February 2020.

This report, our third, was developed to address issues that were raised by Lighting Europe in two sets of comments they submitted directly to the RoHS Committee and the Commission. Lighting Europe is an association representing some of the lighting companies and national lighting associations in Europe, and they are seeking to extend the exemption from RoHS for mercury-containing fluorescent lamps.

The Lighting Europe comments addressed in this report include the following:

1. “Lighting Europe concerns regarding the recent Oeko document dated 8 May 2020,” dated 20 May 2020 and submitted to the RoHS Committee on 20 May by Roumiana Santos of Lighting Europe.

2. “Lighting Europe Calculations - Potential impact of an early phase out of most fluorescent lamps subject to RoHS 2015 exemption renewal requests,” dated 9 June 2020 and submitted to the RoHS Committee on 10 June by Roumiana Santos of Lighting Europe.

This report provides an independent, evidence-based response to the points made in the comments from Lighting Europe.

Past reports on fluorescent lighting under the RoHS Directive:

December 2019: Evidence of the Availability of Mercury-Free Alternative Products to Certain Fluorescent Lamps: Report to the Committee on the Regulation of Hazardous Substances

February 2020: Assessing Annex III Fluorescent Lamp Exemptions in the Light of Scientific and Technical Progress


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