UNION EUROPEENNE DE L’ARTISANAT ET DES PETITES ET MOYENNES
ENTREPRISES
EUROPÄISCHE UNION DES HANDWERKS UND DER KLEIN- UND MITTELBETRIEBE
EUROPEAN ASSOCIATON OF CRAFT, SMALL AND MEDIUM-SIZED ENTERPRISES
UNIONE EUROPEA DELL’ ARTIGIANATO E DELLE PICCOLE E MEDIE IMPRESE
UEAPME’s Position Paper on the EU Eco-label Revised Criteria
for Light Bulbs of November 2001 (discussion paper)
UEAPME would like to express some opinions about the following points:
Regarding the Foreword of the document: “Test procedures (reference paragraph 2.3-pag. 3)
UEAPME thinks that in addition to test procedures required in paragraph 2.3 of the first
document, it should also be necessary to introduce two more key criteria for light bulb:
-level of brilliance (that is calculated in Cd/cm2);
-level of quality in term of reliability.
1) Wider Issues
UEAPME is happy that this section of the document takes in consideration its opinion about
how the revision of the current criteria has to be done. The revision should consider the
different options already mentioned in the first document.
-the current eco-label for light bulbs set revised criteria (option C)
-this revision of the eco-label for light bulbs keeps the existing names and definitions for both
single-ended and double-ended lamps (option A)
-The lifetime of the criteria for light bulbs should be increased to 5 years (option B).
-The mercury content for single ended light bulbs must be reduced to at lest 5 mg or better to
4 mg, and the lifetime has to be increased (option C).
2) Key criteria
The key criteria for light bulbs are:
-Energy efficiency,
-Lifetime and lumen maintenance,
-Mercury content.
About this issue UEAPME would like to express some ideas:
1) The current energy efficiency requirements used in the revised criteria must be retained in
accordance with the EU energy label for light bulbs (Directive 98/11/EC of 27th January
1998)- (option A).
2) The values for lumen maintenance have to remain at the current level (option A).
3) The mercury content for single ended light bulbs must be reduced to either 5 mg or 4 mg,
and the lifetime has to be increased (option C).
4) The mercury content for long life (over 20,000 hours) double-ended lamps must be reduced
from the current value of 10 mg to a maximum of 8 mg (option B).
5) The mercury content for normal life (over 10,000 hours) double ended light bulbs must be
reduced from the current value of 7.5 mg to a maximum of 5 mg, and the lifetime has to be
increased to 12,5000 hours (option B).
3) Other Current Criteria
The current eco-label for light bulbs set criteria for packaging and product information.
UEAPME’s opinions about this item of the document is as follows:
-A criterion on packaging content only set requirements on laminates and composite plastics,
i.e. remove the requirements on recycled content of the cardboard packaging (option B).
-The criterion on product information (user instructions) must be changed to include
information on if the product contains mercury (option B).
4) Possible New Criteria
-A criterion on flame retardants must be included in the revised criteria using the same
wording as that used for other electrical and electronic products (option A).
-A criterion on take-back and recycling be included in the revised criteria using a similar
format to that used for electrical and electronic products (option A).
-A criterion on colour rendering index (Ra) be included in the revised criteria using a different
value to that set by the Nordic Swan (option B).
-The information appearing on the eco-label state that the light bulb has been awarded &n
eco-label because it is very energy efficient, has a ling lifetime, and contains a low level of
mercury (option B).
Brussels, 18th December 2001