Lighting Tutorial [E-BOOK]

8.3 New EU Directive

But by and large it became time to decide about further steps. Therefore the EU repealed the Directive 2000/55/EU and replaced it with the Commission Regulation for implementing the »Ecodesign« Directive 2005/32/EC (ErP Directive – Energy related Products) in the area of lighting components in April 2010. However, other than frequently heard even from lighting experts, this new Directive does not incur any plans to abolish magnetic ballasts!

This new Directive is entering into force in three stages: One year after entry into force preliminary limit values become valid. Three years after entry into force they become one level stricter, and eight years after entry into force these levels will be replaced with yet stricter final limits. This way industry shall be given sufficient time for a conversion. At least this is the principle behind it. The practical implementation is somewhat more lenient. The most substantial novelties are:

  • As an »Ecodesign« directive it does not only provide electrical values but also e. g. maximum limits for the mercury content and minimum values for the lifetime expectancy of lamps.
  • Minimum values for complete luminaires are included – although the only »Requirement« is that »all luminaires … shall be compatible with ballasts complying with the first / second / third stage requirements«.
  • Minimum efficiencies (light output efficacies) are introduced for all common fluorescent and gas discharge lamp types – i. e. for the lamps alone without consideration of the ballast.
  • Apart from this, there are separate limit values for the energy efficiencies of ballasts, measured as the ratio of the lamp power rating divided by the sum of the lamp power rating plus the ballast power loss.
  • A most substantial difference at this point is that the Table 17 of this new implementing regulation (in part reproduced here as Table 8.4) distinguishes between three different power values of lamps: a nominal power, which is, so to say, only the name of the respective lamp, a rated power for mains frequency operation and a rated power for HF operation. The »nominal« power is usually identical with the 50 Hz rated power unless the latter is not an integer figure but has a decimal. Then the decimal is omitted. For instance, an FD-38-E-G13-26/1050 lamp according to ILCOS (International Lamp Codification System) with a power rating of 38.5 W for 50 Hz and 32.0 W for HF has a nominal power of 38 W and is hence called a »38 W (T8) lamp«. In the old Directive the difference between the nominal 38 W and the 32 W HF rating appeared like a 6 W advantage for the HF (electronic) ballast, which it has never ever been. The new approach is to measure, calculate and assess the energy efficiency of a »magnetic ballast for a 38 W T8 lamp« based on an output of 38.5 W and the energy efficiency of an »electronic ballast for a 38 W T8 lamp« based on an output of 32 W, rather than comparing the inputs only.
  • For dimmable electronic ballasts and other remote controllable lamp operating devices there are maximum stand-by losses.
  • Moreover, the power intake – of the lamp as well as the power loss in the ballast – is now to be measured at the point where the light output equals the light output rating of the respective lamp at 25°C ambient temperature. This is a substantial improvement against the present approach to classify only the power intake of the entire system and ignore any possible differences in light output between the uses of different ballasts on the same lamp. Thereby an impartial treatment of both magnetic and electronic ballasts is now granted. The application of two different measures but without respect to the light output comes to an end.

At this point unfortunately the widespread misunderstanding mentioned above arose. The pitfall is that the old designations A1, A2, A3, B1 and B2 continue to be used. A1 continues to stand for dimmable ballasts. Two new classes A1 BAT and A2 BAT (»best available technology«) have been introduced, whereas, again, the former is reserved for dimmable ballasts. However, none of these class designations relates to the old Directive 2000/55/EU, but they are redefined within the new Directive 2005/32/EC. As described above, this is done by means of the ballast energy efficiencies as a percentage value of the real electrical output power by real electrical input power ratio. Now no class is linked to any certain ballast technology any longer, as has been the case so long, such as A for electronic, B (and formerly also C and D) for magnetic, except that A1 and A1 BAT are by definition dimmable ballasts. But their efficiencies are defined in terms of the other classes, as used to be the case before.

Table 8.3: Table 1 of Directive 2005/32/EC

The lamp efficiencies, however, are not divided into classes. This would have gone way too far, since there are so many different types around. These limits must be taken directly out of one of the countless tables, starting with Table 1 (reproduced as Table 8.3 here) splitting double-capped lamps into T8, T5HE and T5HO types. This table reveals rather clearly how far T5HO lamps fall behind not only T5HE but also behind T8 lamps. So T5 lamps are in no way generally more efficient than T8 lamps, as is frequently assumed and alleged (also see section 8.7). This becomes evident at the very first look at the new documentation. The changes in detail are, as far as energy efficiencies are concerned:

Lamp efficiencies

  • First stage requirements: One year after the entry into force of the new regulation T5 and T8 lamps shall have at least the rated luminous efficacies as specified in Table 1 of said regulation (see Table 8.3 here), all measured at 25°C ambient temperature. This appears to be a bit unfair against T5 lamps, though, because for some good reasons they are optimized for an ambient temperature of 35°C.
  • Second stage requirements: Three years after the entry into force the requirements for T8 lamps from the first stage will be expanded to all double capped fluorescent lamps. So this may mean that the T5HO lamp has to go, unless it undergoes some substantial improvement so as to match the requirements for T8 lamps!
  • Third stage requirements: Eight years after the entry into force fluorescent lamps are not faced directly with any additional efficiency requirements. It only says they »shall be designed to operate with ballasts of energy efficiency class at least A2 according to Annex III.2.2«, but this can be said of any common fluorescent lamp already now. Note: It does not say, »The ballast / system shall meet the energy efficiency requirements of class A2 according to 2000/55/EU«, which would have been something entirely different!

Ballast efficiencies

  • First stage requirements: One year after the entry into force of the new regulation the minimum energy efficiency index class shall be B2 (according to Table 17 of 2005/32/EC!) for ballasts covered by Table 17, and A1 for dimmable ballasts covered by Table 19 (of 2005/32/EC, not of 2000/55/EU, which it supersedes! See Table 8.4 here). Dimmable ballasts shall comply with the requirements for class A1 according to Table 19 in 2005/32/EC. Parallel with the old Directive, this implies that the ballast’s efficiency shall match the requirements of class A3 when set to full power and shall use no more than 50% of its full power when set to 25% light output.
  • Second stage requirements: Three years after the entry into force there is no change to non-dimmable ballasts for fluorescent lamps. Limits for high-pressure discharge lamps are upgraded, and the stand-by consumption of dimmable ballast goes from 1 W down to 0.5 W maximum, as used to be the case in the old Directive.
  • Third stage requirements: Eight years after the entry into force the minimum efficiencies of ballasts are:
    η = 71% for ballasts up to 5 W (nominal power),
    η = 91% for ballasts from 100 W upwards,
     for ballasts between 5 W and 100 W.

This calculation of η is called EBbFL in 2005/32/EC. As described above, this approach yields different efficiency values for the same lamp, depending on whether it is being operated with a magnetic or an electronic ballast if different power ratings are given for either of these. The required efficiencies turn out to be a little bit lower for electronic ballasts, which is obvious when one enters slightly lower values of PLamp into the formula.

Table 8.4: Excerpt from Table 17 of Directive 2005/32/EC

So also this new document makes no statement whatsoever about any prohibition of magnetic ballasts. Otherwise what sense would there be in defining new values for classes B1 and B2? Rather, there used to be quite an imbalance to the advantage of electronic ballasts in the old scheme according to Directive 2000/55/EU, which will now have to go in the foreseeable future. While it is always argued among experts that one of the advantages of electronic ballasts was the lower internal power loss, even the old Directive 2000/55/EU stated the very opposite! For instance, it says there referring to a 58 W T8 lamp:

  • Lamp power with magnetic ballast: 58 W,
  • systems power with magnetic ballast (class B1 – old): ≤ 64 W.
  • This allows for a power loss of ≤ 6 W inside the magnetic ballast.
  • Converted to the new calculation method, this would yield a minimum efficiency requirement of
    η ≥ 58 W / 64 W ≈ 91%,
    matching even the new class A2, rather than just B2, which would already satisfy stage 1 of the new regulation! The EBbFL requirement of stage 3 is only:
    η = EBbFL ≥ 89.6%,
    so it is also easily fulfilled by the good old magnetic ballast!

But at the same time it also says in the old 2000/55/EU document:

  • Lamp power with electronic ballast: 50 W,
  • systems power with electronic ballast (class A3 – old): ≤ 59 W.
  • This allows for a power loss of ≤ 9 W inside the electronic ballast!
  • Converted to the new calculation method, this would yield a minimum efficiency requirement of
    η ≥ 50 W / 59 W ≈ 85%,
    passing B2 (new) but failing B1 (new), therefore just about compliant with stage 1. The EBbFL requirement of stage 3 is
    η = EBbFL ≥ 89.1%
    here, hence also failed! In other words: The old Directive allocates a higher class to a poorer ballast and vice versa!

The new classification requires the energy efficiency of a 58 W ballast for a T8 lamp to be 84.7% in class A3 or 86.1% in class B1, respectively. It is a bit confusing why the new class B1 requires a higher efficiency than class A3. In fact it also allocates a higher class to a poorer ballast here. This is the case not with all, but with a number of ballasts and may be a remnant of the old definitions for classes B1 and A3, whenever it is better concealed there (see above). After all this is nothing to worry too much about because these requirements are only a transition to the continuously calculated method of the final stage No. 3. However, it does become evident that a magnetic ballast of class B1 according to the present (old) classification has far lower losses than required by the present (old) class A3; moreover, it even complies with the new A2 requirements! An electronic ballast according to the old class A3, however, just about manages to comply with the new class A3. This does not really look like a prohibition of magnetic ballasts but rather the opposite!

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