GRB Position Paper on Review of ecodesign and energy labelling requirements for lighting products
The Community of European Railway and Infrastructure Companies (CER), the European Rail Infrastructure Managers (EIM), the Association of the European rail manufacturing industry (UNIFE), the International Union of Wagon Keepers (UIP), the European Passenger Train and Traction Operating Lessors' Association (EPTTOLA) and the International Association of Public Transport (UITP) – hereinafter referred to as “the European railway sector” - are fully committed to develop a sustainable and energy efficient railway system by deploying energy efficient measures and energy efficient products. However, the European railway sector is concerned about the envisaged ban of the placing on the market of fluorescent tube T8 lamps in the European Union by 2020 as such a short transition period is not consistent with the sustainability goals of the railway sector. The European railway sector fears that it would go against the intended energy savings and reduction of emissions while causing an important economic burden to the railway sector.
The fluorescent lamp T8 is widely used as the most common lighting system in European
railway rolling stock and infrastructure (e.g. stations, terminals or workshops) and many other sectors. In order to meet the needed lighting performance, specific requirements and legal obligations when replacing T8 by LED, mechanical and/or modifications or even a complete replacement of the installation will be necessary before the end of its useful life cycle in many cases. This would result in reduced energy efficiency, increased consumption of resources and extra cost.
The European railway sector supports a ban of T8 lamps if the transition period is sufficient to allow for a replacement of the lighting installation at its end of life or for bringing them together with other modifications of the fixed installation or vehicles. Therefore, the European railway sector asks for postponing the ban until 2030.