Why is this of interest for the live performance sector?
The EU is reviewing legislation on eco-design which includes lighting; in the course of this process, a special provision for the use of tungsten special purpose lamps which are used for stage lighting was deleted. Without such an exemption, these lights would be banned from the market and would need to be replaced by LED lights.
Some technical reasons why theatres, concert halls and other venues still need traditional stage lighting and cannot replace all lamps with LED technology:
Whereas research and technical development over the past ten years have allowed considerable progress regarding LED spotlights specifically designed for stage lighting, it is still not possible to replace all professional entertainment lighting products (PELP) with LED. The following examples give an insight into the concerns:
Colours: Whereas the currently used PELP offer a wide spectrum of colours which smoothly merge (and this means all elements of the production can be shown in the ideal colour spectrum), the use of LED can lead to distorted colours on the stage.
In addition, LED lights do not have the same range of warm colours as PELP and therefore cannot fully replace tungsten light.
Dimming: LED lights cannot be dimmed such as traditional lights.
High power output: For the lighting of live events, very small halogen lamps with a diameter of 0,5 centimeter are used to produce a high-power output. For those special lamps, there is currently no available replacement with LED technology.
Artistic reasons: The above mentioned technical problems with LED lighting would severely affect the artistic quality of performances, as the richness of lighting for a live event lies in the diversity of light sources, colours and intensity
European legislation on lighting
As mentioned above, lighting – and the issue of stage lighting – is part of the eco-design regulation which is currently reviewed by the EU. For the time being, there is an exemption for special purpose lights (including stage lighting, also called professional entertainment lighting products); however, this exemption has not been kept in a first proposal of the European Commission published at the end of last year.
Our aim is to re-introduce an exemption in the final legislative proposal of the Commission to ensure that traditional light sources (other than LED) can be used for stage lighting.
Please find below links to the currently applicable EU legislation on lighting (including a special provision for stage lighting) and the Pearle contribution to an EU public consultation.
What happens if traditional lighting is prohibited on the stage?
Without an exemption, tungsten light sources and all light fittings/systems would need to be replaced in theatres, venues, concert halls, etc. There is no concrete deadline by when they would need to be replaced, but as we heard from manufacturers, specific light bulbs would not be produced anymore with the reviewed European legislation on eco-design in place (as of September 2020) and probably, theatres and other live performance venues would run out of stock within a few months.
It goes without saying that the replacement of a high number of lamps would have a significant financial impact on live performance organisations and could lead to severe problems, especially for small and mid-scale organisations.
How to move forward on this topic?
Together with a group of stakeholders representing technicians, lighting designers, employers and manufacturers, Pearle* approached the Commission and got a meeting on 17 May to discuss the impact of a missing exemption for stage lighting. As the Commission doesn’t want to have a general exemption anymore (to close loopholes allowing everyone to buy special purpose lamps) we asked to work on a narrow technical exemption which would still allow the live performance sector to work with tungsten lights instead of LED.
Our proposal for an exemption was introduced at the beginning of June. For the time being, we had positive feedback from the Commission and hope that an exemption for stage lighting will be included in the final draft text of the Commission.
As we are currently in the middle of negotiations with the Commission, we would like to ask organisations at national level to wait for the outcome of these talks before taking any actions. We should know by the end of July whether we will have succeeded in including a new exemption for stage lighting.
The Commission will finalise the draft text on eco-design at the end of June / beginning of July to go into the internal consultation process of the Commission (inter-service consultation). Subsequently, the text will be discussed by national experts and Member States will finally vote on in at the beginning of October.
The European Parliament and the Council must give their agreement on the text but can’t amend and change it.
Depending on whether there will be an exemption on stage lighting included in the Commission draft text and whether this exemption is satisfactory, we decide on our further communication strategy and how to approach national ministries and experts.
The Pearle* contribution to the public consultation on eco-design
Overview of the impact on the sector of a missing exemption for stage lighting
The current exemption for stage and studio lighting from 2012:
Commission Regulation (EU) No 1194/2012 of 12 December 2012 implementing Directive 2009/125/EC of the European Parliament and of the Council with regard to ecodesign requirements for directional lamps, light emitting diode lamps and related equipment.
See: article 2 4(b) (ii)