PUBLIC CONSULTATION ON MINIMUM ENERGY PERFORMANCE STANDARDS AND MANDATORY ENERGY LABELLING FOR GENERAL PURPOSE LAMPS

The National Environment Agency (NEA) of Singapore is seeking feedback on a proposal for minimum energy performance standards (MEPS) and mandatory energy labelling scheme (MELS) for general purpose lamps.

Introduction
 
The National Environment Agency (NEA) of Singapore is seeking feedback on a proposal for minimum energy performance standards (MEPS) and mandatory energy labelling scheme (MELS) for general purpose lamps.
 
Background
 
2        Lamps are common devices found in homes and buildings. NEA’s household energy consumption study that was completed in 2012 found that lighting accounted for 4.3% of household consumption and was among the top 5 energy-consuming household appliances and devices (refer to Annex 1 for a breakdown of household energy consumption by appliance).  Lighting also accounts for about 15-20% of the consumption in commercial buildings[1].
 
3        The types of lamps commonly used for general purpose lighting in households and buildings are:
 
            a)   incandescent lamps (tungsten filament & tungsten halogen),
            b)   compact fluorescent lamps (CFL), 
            c)   non-directional light emitting diode (LED) lamps, and
            d)   tubular fluorescent lamps.
 
4        Among these lamps, tungsten filament lamps have the lowest efficacy[2] and consume the most energy for the same light output (refer to Annex 2 for comparison of different lamp types).
 
5        CFLs have a higher efficacy than incandescent lamps.  They require electronic ballasts but these can either be a separate device that the lamp is electrically connected to, or integrated with the lamp.  CFLs with integrated ballasts, or CFLi, were introduced by manufacturers as a direct replacement for common incandescent lamps.
 
6        LED lamps have a higher efficacy than both incandescent lamps and CFL/CFLi. Similar to the CFLi, LED lamps that are meant to replace incandescent lamps have an integrated control gear. They also last about 23 times longer[3] than tungsten filament lamps, 11 times longer than tungsten halogen lamps and 3 times longer than CFLi.
 
Rationale for Introducing MEPS and MELS for Lamps
 
7        From July 2015, incandescent lamps, CFLi and LED lamps used for general lighting purposes will be subjected to MEPS and MELS.  The objective of mandating MEPS for lamps is to eliminate inefficient products in the market so that consumers are not locked into high energy and life cycle costs from inefficient lamps.  MELS will further improve these gains as the energy efficiency rating on the energy labels will encourage consumers to select more efficient lamps.
 
8        In general, energy inefficient tungsten filament lamps have low upfront costs but high energy costs and short operating lifespans. The energy cost over the lifespan of such lamps significantly outweighs the cost of the lamp.  The total cost of ownership of a tungsten filament lamp is much higher than alternatives such as tungsten halogen lamps, CFLi and LED lamps (refer to Annex 3).  For example, an LED lamp can save a household about $14 for every thousand hours of operation of the lamp. Therefore, there is a good case to mandate an efficiency standard for lamps so that only efficient lamps can be sold.
 
9        While most tungsten filament lamps will be phased out with the implementation of MEPS, they can be readily replaced with tungsten halogen lamps, CFLi and LED lamps. CFLi and LED lamps are cost effective alternatives to tungsten filament lamps because they last longer, the operating cost is low and the light quality is good.  Tungsten halogen lamps are also cost effective, have the same light quality as tungsten filament and are also dimmable.
 
Scope of MEPS and MELS for Lamps
 
10      The proposed regulations will cover incandescent lamps, CFLi and LED lamps. Tubular lamps (e.g. circular and linear fluorescent lamps) are not covered (refer to Annex 4 for lamps that will not be covered).  Lamps that are uncommon or intended for special purposes, will also not be covered under MEPS as:
 
            a)   there are no substitutes if the lamps become unavailable,
            b)   it is not cost-effective for consumers as the operating time is short and, hence, the life cycle savings are low, or
            c)   the administrative burden on manufacturers would be excessive because the volume traded is low.
 
Proposed Minimum Energy Performance and Quality Requirements
 
11      In order to align with international standards, the proposed MEPS levels are equivalent to current MEPS levels for incandescent lamps, CFLi and non-directional LED lamps in the EU. The MEPS cut-off levels for the different types of lamps are shown in Annex 5.
 

12      As the upfront costs of CFLi and LEDs are higher, reliability and quality standards, such as minimum requirements for lumen maintenance and lifespan, are necessary to ensure that the life cycle cost benefits of implementing MEPS are realised and consumer confidence is not undermined by poor quality lamps. Therefore, in addition to efficiency standards, it is proposed for CFLi and LED lamps to meet quality requirements in terms of lamp survival and lumen maintenance standards: 

 
13      An energy label is to be affixed or printed on each lamp packaging. The energy label and rating system are shown in Annex 6.  The labelling regime consists of three lamp efficacy levels, each denoted by a different number of ticks.  The highest efficacy level will be denoted by three ticks and the lowest by a single tick.  Tungsten halogen lamps will mainly be rated at the one-tick level based on the currently achievable efficacies. CFLi and LED lamps will mainly be rated at the two and three-tick levels depending on the efficacies of the specific models.
 
Transitional Provisions
 
14      To allow lamp importers, manufacturers and retailers time to clear their existing stocks of lamps, products that are supplied in the market before 1 Jul 2015 will be exempted from the MEPS and MELS regulations for a year.
 
Registration and Testing
 
15      Suppliers of lamps must register their products with NEA and produce test reports of lamp efficacy and quality to demonstrate compliance with MEPS and quality standards. Test reports from one of the following categories of testing laboratories will be accepted:
 
            a)   manufacturer’s in-house testing laboratories,
 
            b)   testing laboratories in countries other than Singapore that are accredited by their local accreditation bodies, which have signed a Mutual Recognition Arrangement with the Singapore Accreditation Council (SAC), to carry out the test in accordance with the applicable test standards, or
 
            c)   testing laboratories that are accredited by the SAC to carry out the test in accordance with the applicable test standards.
 
16      The International Electrotechnical Commission (IEC) and International Commission on Illumination (or Commission Internationale De L’Eclairage, CIE) standards, which are internationally recognized test standards, will be adopted as the test standards for incandescent lamps, CFLi and LED lamps.
 
Moving Forward
 
17      Moving forward, NEA will study the feasibility of extending MEPS and MELS to tubular fluorescent lamps and ballasts, and regularly review the efficiency standards of general purpose lamps.
 
Public Consultation
 
18      Interested parties may submit feedback to Frankie_Foo@nea.gov.sg. The consultation exercise will end on 9 March 2015.
 
19      To ensure that the consultation is productive and focused, respondents are requested to observe these guidelines when providing their feedback:
            •     Please identify yourself as well as the organization you represent (if any) so that we may follow up with you to  clarify any issues, if necessary.
            •     Please be clear and concise in your comments.
            •     Please focus your comments on the proposal and how it can be improved.
            •     As far as possible, please substantiate your points with illustrations, examples, data or alternative suggestions.
 
20      This proposal is released for the purpose of consultation. All comments received during the consultation exercise will be reviewed thoroughly and may be incorporated into the final measure.
 

 The National Environment Agency
 17 February 2015

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EndNote:
[1] Singapore’s Second National Communication Under United Nations Framework Convention on Climate Change, 2010

[2] Lamp efficacy is defined as the lumen output per Watt of power consumption.

[3] NEA Survey of Lamp Suppliers in 2014