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€5,5 bln lost in a year as EU fails to act on mercury-based lighting ban

(eceee news, 29 Jan 2021) Banning mercury-based light sources by September 2021 would save more than 300 TWh of electricity by 2035 in the EU, according to the European Commission’s own assessments in July 2020 as it mulled a ban on mercury in lamps under to RoHS Directive. However, no regulation has been proposed to date. The delay will cost at least 5.5 bln euro in missed energy savings the first year, with rising annual costs for each year of delay.

The new calculations on the costs of delayed regulation have been carried out by CLASP, an expert NGO focused on product standards and energy labelling. The report follows a July 2020 assessment and market survey, where the Swedish Energy Agency and CLASP jointly proved that more than 90% of mercury-based lamps on the EU market could be replaced by LED lamps as direct drop-in replacements, with short paybacks and significant environment, energy and climate benefits. For instance, the savings would be equivalent to retiring 15 large coal-fired power plants.

The RoHS directive and the Minamata convention

EU’s RoHS Directive – Restriction of the use of certain Hazardous Substances in electrical and electronic equipment – bans six extremely dangerous groups of chemicals in electrical and electronic products. Mercury, a neuro-toxin that causes nervous, digestive, immune system and other damage, is one these substances.

Under the RoHS Directive, exemptions are granted if it can be proven that a banned chemical is needed for a certain product and there is no viable alternative. Technical feasibility and economic assessment are both part of that review. Currently, mercury-based light sources, including fluorescent lamps, are granted an exemption. The current exemption was adopted 2010 and has been under review since 2015. According to the RoHS Directive, exemptions should be reviewed every five years, so a new exemption decision is greatly delayed.

In May 2017, Europe also ratified the Minamata Convention, a global convention restricting the use of and exposure to mercury.

July 2020 analysis: 300 TWh savings by 2035

In July 2020 the European Commission’s DG Environment published an updated analysis of the costs and benefits of ending the current exemption for lighting products. The DG Environment assessment included a detailed analysis of the financial, energy, climate and mercury-pollution impacts of phasing out the three most common types of mercury-containing lamps – T5 linear fluorescent, T8 linear fluorescent and pin-based compact fluorescents. These lamps are typically replaced with retrofit LED (light-emitting diode) lamps, which contain no mercury, consume half as much energy for a given light level, and last 2–3 times longer.

The 2020 report found that if DG Environment eliminated these three fluorescent lamp types effective in September 2021, then by 2035 there would be an EU-wide cumulative reduction of electricity consumption of more than 300 terawatt-hours and 92 megatonnes of associated carbon dioxide emissions. The ban would generate €29.9 billion Euros in net financial savings (including costs associated with lamps, luminaires and labour), and 2.88 tonnes less mercury would be placed into circulation in Europe. In addition, close to five tonnes of mercury would be avoided from coal-fired power plants due to the calculated 309.7 TWh of electricity savings[1]. It should be noted that most of these reductions would occur early in the phase out, and with a declining share of coal in Europe’s power mix the opportunity to get rid of these air-borne mercury emissions are better if the phase out starts early.

Since publishing that report, the Commission has not acted on the exemption, and therefore 2021 is no longer a realistic phase-out year. CLASP revisited the Oeko-Institut analysis to update the potential savings under a later phase-out date, and to calculate the costs of this ongoing delay. CLASP claims it has used the Commission’s own spreadsheet for assessing the consequences of the delays.

The cost of delay

The recalculation of the Oeko-Institut data for a one-year, two-year or three-year delay from the previous analysis shows significant costs to European citizens in terms of excess energy use, increased pollution, and higher cost to consumers.

With one year of regulatory delay, Europe loses €5.6 billion in cost savings due to excess energy use and adds 570 kg to its mercury pollution burden not counting mercury emissions from power plants [2]. As the delay lengthens, the cost goes up.

“The analysis shows why time is of essence”, says Peter Bennich, senior advisor at the Swedish Energy Agency and co-author of the 2020 report mentioned above. “Every year we fail to switch to more efficient LED light sources we keep wasting money and energy, and we keep adding mercury and carbon dioxide emissions. So, while waiting a year or two may sound harmless, it isn’t.”

If the Commission delays the phase-out of fluorescent lamps under RoHS by one year, so it becomes effective in 2022, the impacts were calculated as follows:

• 2 TWh of increased electricity use over the year, or about equal to the annual electricity consumption of Switzerland
• €5.6 billion savings lost; €465 million savings lost per month; €15.5 million savings lost per day
• 570 kg of additional mercury pollution from lamps alone.

If these fluorescent lamps are eliminated effective in 2023, delayed by two years from the original analysis, the impacts were calculated as follows:

• 120 TWh of lost electricity savings, or about equal to the annual electricity consumption of the Netherlands.
• €11.7 billion savings lost over two years; €487 million savings lost per month; €16.2 million savings lost per day
• 1060 kg of additional mercury pollution from lamps alone.

If these fluorescent lamps are banned in 2024, delayed by three years from the original analysis, the impacts were calculated as follows:

• 164 TWh of lost electricity savings, or about equal to the annual electricity consumption of Poland
• €16.9 billion savings lost over three years; €469 million savings lost per month; €15.6 million savings lost per day
• 1430 kg of additional mercury pollution from lamps alone.

Reading

• Memo by CLASP on the costs of delaying the phase out of mercury-based lamps (Jan 2021).
• Clarifications on Lighting Europe’s Comments to the RoHS Committee by CLASP and the Swedish Energy Agency (July 2020).
• DG Environment assessment on costs and benefits to end mercury based exemption under teh RoHS Directive (July 2020).
• Minamata convention web site.

Footnotes

[1] Although the Oeko-Institut analysis does not consider avoided mercury emissions from power stations due to electricity savings, the Commission’s Joint Research Centre (JRC) estimates that on average each kilowatt-hour produced in Europe releases 0.016 mg of mercury into the air from the coal power stations in the generation mix. For a discussion of those additional mercury emissions, see Assessing Annex III Fluorescent Lamp Exemptions in the Light of Scientific and Technical Progress, CLASP, Feb 2020.

[2] For one year of delay, there is an additional 995 kg of additional power plant-related mercury emissions; for two years of delay there is an additional 1920 kg; for three years of delay there is an additional 2624 kg. See above source for details.