Fluorescent tube ban: RoHS and ecodesign – switch to LED with sensors now

Fluorescent tubes and compact fluorescent lamps for general lighting may no longer be placed on the EU market since 2023. The RoHS exemptions for mercury expired on 24 February 2023 for compact fluorescent lamps and on 24 August 2023 for the common T5 and T8 tubes; since 1 September 2023, the Ecodesign Regulation (EU) 2019/2020 has required T8 tubes to achieve the same efficiency that also applies to LEDs. Existing lamps may continue to be operated, but replacements are becoming scarce. If you are converting halls or offices to LED now, you should plan the sensors at the same time.

Why fluorescent lamps are disappearing from the market

Fluorescent lamps produce light with the help of mercury. The RoHS Directive 2011/65/EU restricts mercury in electrical and electronic equipment; lamps were previously permitted through time-limited exemptions in Annex III. In December 2021, the Commission decided not to renew these exemptions for general lighting because, according to its assessments, mercury-free alternatives are widely available. The corresponding Delegated Directives were published in the Official Journal on 24 February 2022.

In parallel, the Ecodesign Regulation (EU) 2019/2020 has governed since 1 September 2021 how efficient newly marketed light sources must be. Together, these two sets of rules have sealed the end of the conventional fluorescent lamp in general lighting.

The dates at a glance

In addition, there is the Ecodesign Regulation: since 1 September 2023, T8 tubes of 2, 4 and 5 feet in length have been subject to an efficiency threshold of 120 lm/W in the calculation formula, the same value that the regulation applies to "other light sources" such as LEDs. Previously, it was 89.7 lm/W for T8.

Lamps for special applications are subject to their own rules, some of which differ. The table applies to general lighting, in other words to the lighting in offices, halls, corridors, shops and schools.

Remaining stock: what is permitted

The substance restriction is linked to placing on the market. The German transposition, the Electrical and Electronic Equipment Substances Ordinance (Elektro- und Elektronikgeräte-Stoff-Verordnung, ElektroStoffV), defines this as making a device available on the market for the first time. It follows that:

• Operation: you may continue to use installed fluorescent lamps until they fail. There is no obligation to replace existing installations.
• Sell-off: retailers may continue to sell lamps that were first placed on the market before the cut-off date.
• Supply: newly produced fluorescent lamps for general lighting no longer come onto the market. Replacements are only available while stocks last.

What this means for halls

Warehouses, production halls and logistics halls often have long continuous lighting rows with T5 or T8 tubes. If a tube fails there, finding a replacement becomes a procurement issue. At the same time, halls are where a control system makes a particularly big difference: aisles and racking zones are often occupied only briefly, and lighting rows near windows or rooflights benefit from daylight.

For the conversion in halls, the following approaches have proven effective:

• Create zones according to use: control racking aisles, traffic routes, order picking and loading areas separately.
• Plan in high bay sensors: for large mounting heights, sensors such as the EFS106 for 5 to 22 m are suitable. Details in the guide High bay sensors for warehouses.
• Background lighting instead of darkness: in areas with vehicle traffic, a reduced background light level is often more sensible than switching off completely.

You can find more application examples under Warehouses and logistics.

What this means for offices

In offices, fluorescent lamps are mainly found in recessed grid luminaires with T5 or T8 tubes and in downlights with compact fluorescent lamps. This is precisely where it pays to look beyond replacing the lamps: with hybrid working, meeting rooms, individual offices and corridors are often empty, and window workstations have enough daylight for much of the day.

• Presence sensors per room or zone switch off or dim the lighting when nobody is present, for example the IFS105SE for mounting heights of 2 to 5 m.
• Daylight-dependent control adds only the light that is missing near windows, see Daylight harvesting.
• Maintain illuminance levels: the control system must ensure the values required by ASR A3.4 and DIN EN 12464-1.

Further information is available on the page Offices and workplaces.

LED tube or new luminaire – and why sensors are part of it

There are basically two options: LED replacement tubes in existing luminaires or new LED luminaires. Whether replacement tubes are permissible and sensible in a particular luminaire depends on the luminaire, the ballast and the manufacturer's specifications. For lighting control, new luminaires with dimmable drivers are usually the better basis, because they can be dimmed continuously. Luminaires with an integrated sensor are described in Luminaire level lighting control (LLLC).

LEDs reduce the power, and the control system reduces operating hours and light levels. Depending on the building and its use, the combination results in a savings potential of up to 92 % compared with an uncontrolled existing installation; the savings calculator provides an estimate for your building.

How we support you

We survey your existing lighting on site, plan the luminaire replacement, sensors and zoning together and show you the result in 3D in advance in Sensora. We usually carry out the installation ourselves, or your own electrical contractor can do so if you prefer. We implement every project with the AU-Manager, so occupancy detection, zoning and monitoring are included and you can measure the savings after the conversion. You can find the current status of obligations under the GModG in German energy laws and lighting control. For your project, you can reach us via our contact page.