Members of the lighting industry recently gathered for an information session in Pretoria held jointly by the National Regulator for Compulsory Specifications (NRCS), the Department of Energy (DoE) and the United Nations Development Programme (UNDP). Information shared was around the planned regulation of general service and directional lamps for general illumination using incandescent, halogen, fluorescent, high intensity discharge, LED, and other light sources.

Proposed lighting regulations raise concerns

The significance of the topic was clearly evident from the overwhelming attendance, and the room quickly filled beyond capacity with major players from the lighting industry. Theo Covary, Project Manager at the UNDP explained that while the country’s Standards and Labelling Programme in the past has focused primarily on white goods, lighting has long been on the radar, and will, within the next few years, become the first electrical product to be regulated in the SADAC region. He noted that the NRCS was fully behind the process of including new technologies in its regulations. “As we speak though,” he said, “there are still a lot of non-compliant lighting products entering the country and the UNDP has assisted in destroying the millions of CFLs that have been seized.”

He believes that the industry needs to be regulated to level the playing fields, with the mandate of providing quality, affordable, energy efficient lighting to the public. Education will be imperative, and social media campaigns – seen as the best way to connect with the general public – will focus on the reasons to move away from CFLs. A labelling system will also be developed educating consumers on, for instance, how to buy a lamp, lifecycle costing and the difference between watts and lumens.

Langa Jele, Technical Specialist at the NRCS, explained that while there were already regulations in place for incandescent and CFLs, the new regulations would be based on a minimum energy performance standard, effectively banning older technologies.

Although much of the groundwork has been done, including feasibility studies, there is still a lot to do before the regulations are approved, including stakeholder engagements, risk assessments and the time consuming approval process. Jele believes that a date of November 2019 for final publication of the regulations is feasible.

Michael Scholand, an industry expert from the United States presenting his experiences in other countries, noted that the decision to regulate lighting was in line with what was happening globally. “The best approach is to define general lighting, define the parameters around the categories the products fall into in the regulations and then, in the regulations, set the requirements for, for instance, efficacy levels, which will have an impact on which technologies can be utilised.”

Heated session

A heated question and answer session followed where concerns were raised about the proliferation of illegal exports, the cost implications of newer technologies for the poor, and the impact the regulations would have on manufacturers.

“I think it is high time the NRCS regulated LED lamps. This is within their primary mandate to protect the consumer, environment and to ensure fair trade,” said Joel Ndaba, Quality Director at TACS Laboratories, a SANAS accredited test laboratory which offers conformance testing on electrical products and materials. “As much as LEDs are considered to be efficient, not every LED is of good quality.” He continued, “According to photo-biological safety requirements (IEC/TR 62471-2), UV rays generated by a non-laser light source, such as an LED, have negative effects on human eyes and skin. The electromagnetic interference of such LED globes is also a health risk.

“With the shift from traditional (HID, fluorescents and incandescent lamps) to solid state lighting, if SSL is not regulated, South Africa could become a dumping ground for poor quality LED lamps. It is important for South Africa to build capacity to ensure the regulation of such products is effective, because we seem to be behind schedule compared to other countries, which have phased out old lighting technologies such as incandescent lamps,” Ndaba said.

SAFEhouse’s concerns

When approached for comment, Connie Jonker of SAFEhouse said he had been involved for the past year or so in discussions with representatives of the UNDP with regard to legislation and had, in all the discussions, raised his concerns about the incapacity of the NRCS to regulate products effectively. “It is generally accepted that any electrical product, and this applies even more to electric lamps, can only be regulated through extensive market surveillance and testing of available products. Without extensive test programmes, the proliferation of substandard products will increase. Although energy efficiency labelling is put forward as a success story, and similarly that of the control of CFL lamps, the real facts and the impact on the industry are not reflected.”

He said that from the NRCS Annual Report 2015/16, it was evident that only R3.3 million was budgeted for testing on behalf of all departments in NRCS. “The LoA (Letter of Authority) process, which has been enforced since the formation of NRCS in 2008, has been a complete failure. Only about 16 000 LoAs are processed per year for a range of regulated products that could be in excess of 250 000,” he said. Jonker continued, “Life expectancy and lumen maintenance testing takes time and requires extensive test facilities.

A 6000 hour test takes approximately 11 months, while LED lamp manufacturers claim life expectancy of over 15 000 hours. With the capacity limitations of local accredited test labs, the non-recognition of manufacturer’s self-declaration of compliance, and the non-recognition of SABS Certification, the introduction of such a compulsory specification only benefits the NRCS through income from levies and LoA approvals. SAFEhouse believes that in the end, the consumer pays dearly for NRCS intervention, without getting a better product.”

Barry O’Leary, Jonker’s colleague at SAFEhouse concurred, “As I mentioned in the session, SAFEhouse has a major concern with the market surveillance of these products. Langa Jele and Stephinia Teffo from the NRCS both mentioned that the NRCS would like to work with industry and individuals to reduce/eradicate the number of non-compliant products that enter the country and those products that require LoAs. Unfortunately, ‘working together’ does not work at the moment.”

There is no doubt that regulation of the lighting industry is sorely needed, and Sparks Electrical News will be following this topic closely over the coming months.

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