If you think the lighting industry is subject to a lot of regulation now, to paraphrase a classic rock song, ‘you ain’t seen nothing yet’.
In March of this year, the European Commission adopted a proposal for a comprehensive new legislative package called the Sustainable Products Initiative (SPI). Part of the Commission’s flagship Green Deal, the SPI essentially aims to ensure that only the most sustainable products are sold in Europe. To do this, the proposals included in the SPI look to empower consumers to save energy, repair products, and make smart environmental choices when shopping for new products.
Of particular interest to the lighting industry is the SPI’s proposal for an Ecodesign for Sustainable Products Regulation (ESPR). This would repeal and replace the current Ecodesign Directive that our industry is by now very much familiar with. Like the Ecodesign Directive, details as to what is and is not sustainable will be decided at the product level. The ESPR will, without a doubt, require even more from the lighting industry.
In addition to the energy efficiency requirements of the current regulation, the ESPR will include specific requirements relating to life cycle, durability, use of recycled content, repairability, and raw material usage. All these new sustainability requirements will be evaluated and introduced in product specific rules, also for lighting. Thanks to our industry’s wealth of experience with the Ecodesign Directive, and LightingEurope’s leadership on the file, LightingEurope is well-positioned to shape the next generation of lighting requirements.
But the ESPR is just the tip of the iceberg. There’s a whole slew of sustainability initiatives on the horizon, each of which will have a direct impact on the lighting industry. Take for example the initiatives designed to empower consumers by preventing so-called ‘greenwashing’. Under these proposals, companies will not only be required to substantiate any claims relating to a product’s sustainability, they’ll have to do so using the methods set out in the Substantiating Green Claims initiative. Any claim that does not follow such methods will be deemed misleading and be subject to sanctions.
Other key initiatives include:
On top of these new initiatives, the European Commission is also expected to review and update such regulations as the Waste Framework Directive (WFD); Waste Electrical and Electronic Equipment (WEEE) Directive; Restriction of Hazardous Substances (RoHS) Directive; and Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation.
What does all this mean for the lighting industry? To start, companies will need to rethink how they design their products. In addition to being energy efficient and complying with the recently introduced quality parameters and labelling requirements, products will also need to be designed so that they are repairable and offer increased durability – both of which will require that necessary spare parts are available for several years.
While the latter could open new revenue streams for OEMs, they must also be prepared to compete against other companies producing and selling these spare parts. Recruiting and holding on to qualified staff experienced in sustainable product design and manufacturing will also become increasingly challenging.
The EU regulatory drive on sustainability is directly impacting all sectors, from textile to electronics or cement, and all these companies are quickly trying to build up capacity internally to stay ahead of the regulatory trends and the market. Sales may decrease, not only because products are more durable but also because their cost is very likely to increase. Customers will ultimately have to cover the cost of the additional investment needed to redesign products and processes, and regulators acknowledge this. The amount of information that companies will be obliged to collect and make available will increase exponentially. LightingEurope expects that today’s Energy Label will evolve into a Sustainability Label that could also include a repairability score and a lifecycle assessment. Furthermore, as previously mentioned, companies must ensure that any and all sustainability claims can be fully substantiated with evidence.
Last but not least, we expect to see Digital Product Passports (DPP) used to report information for each single product – including every substance found in a product. Considering that many electronic products contain up to 4,000 different substances, DPP reporting requirements could end up being extremely cumbersome.
Not only is the regulatory landscape extremely complex, it is also moving fast. While the review of ecodesign rules for light sources is set to begin in 2025, the taxonomy reporting obligations have already started this year. More so, all the obligations mentioned are expected to apply by 2026 and 2027 – less than four – five years from today.
LightingEurope is an established credible voice in the EU sustainability debate, regularly talking with regulators, NGOs and other trade associations to explain the specificities of lighting and voice our members’ recommendations. LightingEurope members receive regular updates on regulatory trends and latest developments, giving them the information they need to be proactive – not reactive – and to translate sustainability requirements into business opportunities.
