About the questioning of the European Commission lighting directive

La Lettre AFC n°287

[English] [français]

The association of lighting designers (ALD) alerted the profession against a possible revision of the European Community lighting directive to the entertainment (Scenic, event, film and TV). I signed the petition from the ALD and I participated in the European Union survey to defend the LEDs and tungsten lighting technologies. Imago asked me for my opinion on the question. And here is what I replied.

The ALD put together this little summary :
Ten point summary if you read nothing else !
1. New regulations proposed for September 2020 will impose a minimum efficiency of 85 lumens per watt and a maximum standby power of 0.5W on all light sources (lamps or self-contained fixtures) to be sold in the EU.
2. The existing version of these regulations includes an exemption for stage lighting. The new regulations do not (though they do include exemptions for video projection, and suggest an exemption for stage lighting that appears to have mis-understood the light levels/power requirements of most theatrical lighting fixtures).
3. No tungsten fixtures meet this requirement. Many LED-based entertainment fixtures do not meet those requirements. After September 2020, no new stocks of such equipment can be supplied to the market in the EU.
4. Manufacturers suggest that the limits of optical design and LED efficiency mean that they will not be able to create certain types of fixtures that do meet the requirements by September 2020.
5. Nothing in the rules stops you from using existing fixtures. But bulbs can’t be supplied to market, and once you can’t get new bulbs, existing fixtures become worthless - effectively scrap. It is unknown how long existing stocks of bulbs will remain available.
6. Replacing your existing fixtures might well mean replacing your entire dimming and control infrastructure.
7. All this for power savings that might be relatively small, given the way entertainment lighting is typically used, and will likely be far outweighed by the scrap created and the energy required to manufacture and distribute new fixtures.
8. Important tools from a lighting designer’s toolkit will be lost within the EU, some forever.
9. This will dramatically affect performance venues and productions of all types and scales, including new and existing (long-running, long-standing rep) productions
10. There are very few precedents for technologies to be banned, if they are not unsafe to use.

Imago asked me for my opinion on the question, as they had to do to many others. And here is what I replied, not that it’s a more important opinion than others but that’s the only one I have known and that I can publish without permission.

When it comes to entertainment and film shooting, lamps are used for the effects they achieve and the type of specific light they produce. The efficiency is not the main criteria when it comes to Art. None of the LED products are reaching 85 lumens per watt and yet they are very useful in bringing a vast panel of colors, and much quicker than mechanical color changers to change colors, and in a much more fine tuning way. Tungsten in film is still the highest CRI, the standard of 100, and despite its low efficiency, it has a quality that can’t be explained but only felt. HMIs have the fullest spectrum in daylight and are preferred by many cinematographers and photographers around the world.

Because lighting is about effects, skin tone, creating emotions and telling a story, it needs to have as many diverse tools as possible. Some existing lighting technologies can’t just be replaced, because they are unique and needed as long as the minds of a creative people are using them. CRI, unique light quality and flexibility are important when it comes to creation, definitely more than saving a few watts. Gold is replaceable by alternative materials, which are more shiny and easier to maintain, but it is still the favored choice of jewels and watchmakers.

Productions today are already using less power than they used to. Generators are shrinking down and the highest wattage is sometimes a 4K when it used to be an 18K. Obviously big lights are still used when it comes to competing with the sun but they tend to be used for specific days of shooting only. Digital cameras have a standard sensitivity of 800 to 2.000 ISO, with much higher possibilities enabling productions to use already less light than before. I am not sure this is a good thing to shoot a night scene with available light only just because it saves time (and money). Because not lighting a background is losing some story telling elements. It’s like a painter who would decide to do a fog in the background of their painting because it saves them from painting a complicated landscape or monument. So yes, sometimes, even if we work in an eco-responsible spirit, we need to avoid compromising, as it can become a censor to creativity.

I signed the petition from the ALD and I participated in the EU survey to defend the LEDs and tungsten lighting technologies, even though HMI is over 90 lumen per watt. None of our HMIs is concerned about this directive but still it’s important to stand for freedom of using our favorite tools for the right situation. We are working on LED products, which will not meet the criteria. With LEDs, the more efficient you go, the less CRI you get and we intend to go for quality over quantity.
I do not think we should worry too much about this, though. There are a lot of jobs at stake in big companies such as Osram, Philips, Cree, Etc, Robe, Martin, Arri… and there cumulated multi-billion € turnover is capable of making a point.