NEW LAMP REGULATION IN PERSPECTIVE

The introduction of Minimum Energy Performance Standards (MEPS) for electrical appliances to advantage consumers and alleviate the energy crisis has now been extended to include the energy efficiency requirements for General Service Lamps (GSLs).

This project has the potential of significant savings given that energy consumption for lighting is estimated at >15 % of generated electricity. LED technology has rapidly become the preferred general lighting source due to its efficacy, increased safety, and longevity. The transition to this SSL technology on a compulsory basis has been internationally promoted and has initiated the development of the new South African compulsory specifications VC9109 and VC9110, covering the performance and safety of general service lamps, which have become effective from 24 May 2024.

When the compulsory specification for CFLs VC9091 was introduced during 2010, the transition to this “energy saver lamp” was aggressively promoted by the ESKOM Demand Side Management project through free distribution of CFLs to large parts of the community. This lamp type, due to its mercury content, has now become the “mercury polluter” – to be banned by means of specifications VC9109 and VC9110 which are physically banning all tungsten and compact fluorescent lamps by means of the minimum light output requirement of 90 lm/W.

Ironically the contribution of fluorescent lamps as a “mercury polluter” should be compared with those of the coal-powered energy plants and the mining and cement industries. Putting this in perspective – the daily mercury pollution caused by ESKOM’s power stations is equivalent to the mercury content of 5 million CFLs of which a large proportion of mercury can still be extracted through recycling processes.

Industry Support

In principle, the lighting industry is supporting the introduction of MEPS provided that rational and effective regulatory control measures are introduced and maintained. Unfortunately the present regulatory model, which is falsely purported by NRCS to be based on international best practice is in urgent need of review. It is lacking effective monitoring, verification and enforcement as is clearly evident considering the high rate of non-compliance of regulated products still available on the South African market which place the consumer and environment at risk.

Lamp regulation in perspective

IMPACTS

NCRS CONSULTATIVE PROCESSES

During the comment stages of the 2021 specifications, luminaire and lamp suppliers requested transitional measures to phase out existing stock. However, the NRCS has again taken the consultation process to the extreme, failing to reach consensus through open and constructive debate to determine the readiness of affected stakeholders, test laboratories, and the NRCS.

Despite clear feedback to NRCS that industry stakeholders were not ready to comply fully due to some outstanding matters in the specification, the NRCS was adamant to push ahead to meet the deadline.

This has led to crisis management as all lamps, including LED lamps presently in the market, are non-compliant. After serious debate with NRCS, the associations IESSA and SAFEHOUSE representing the leading lamp suppliers, insisted on a written directive from NRCS regarding LOA approvals for imports and Sales permits for existing stock. This directive which still raises significant operational concerns forced upon lamp suppliers was only given on 22 May 2024 two days prior to the VC9109/9110 implementation date.

 

Conformity Assessment - Safehouse

LOA and Sales Permit Applications

While many suppliers had timeously applied to the NRCS for Letters of Authority (LOAs), none had been issued yet on the date the directive was circulated. Due to mandatory energy label requirements which were still being finalised, this hold-up in addition to the administrative delays which requires 90 days for LOA processing, has seriously impacted on lamp suppliers.

Lamp Regulation in Perspective

The directive issued by NRCS that sales permits are required for all lamps ( including LEDs which have not been regulated before) presently in the trade and the cut-off date which was now extended to 25 May 2025, adds another administrative and financial burden to both the supplier and the NRCS.

As the National Consumer Protection Act (NCPA) already applies to all consumer products, the directive of the NRCS to also require sales permits together with either a safety test report or a Supplier Declaration of Conformity (SDoC) for existing stock demonstrates the overarching urge to regulate, without adding value to the protection of the environment and the public.

Safety of GSLs

Lamp regulation

The annual Lamp imports into South Africa is estimated at 180 million of which > 50% are GSLs.

If lamp safety really was an issue, one would expect regular reporting of hazardous situations due to lamp failure.

After researching the safety risk matter in some detail, it has been concluded that the problem lies with the NRCS risk assessment methodology being used to determine justification to regulate products due to their safety risk which then results in an irrational regulatory process.

Following the NRCS Risk based approach, the GSL project has been categorised as “high risk”, being a new regulation, irrespective of the actual product risk of non-compliance.

Conclusion

  1. While product safety specifications are essential to ensure constructional compatibility for example between lamps and lamp holders, it does not always justify the same level of regulation which the NRCS applies to low risk and high-risk products.

2. Suppliers of lamps and electrical products in general should start implementing procedures and concepts promoting self-regulation or self-compliance based on SANS 17050: ‘Supplier’s Declaration of Conformity.’

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