We the undersigned strongly request that the EU Cultural and Energy directorates maintain the exemption afforded to all stage lighting equipment (EN 60598-2-17, "IEC 60598-2-17:2017) from legislations which would prohibit their manufacturing and sale.

The proposals in the Energy Directorate’s Eco-design Working Plan 2016-2019 pose an enormous threat to the way theatrical productions are presented. The impact of these proposals across Europe would be immediate, and overwhelming.

Tungsten and Arc light bulbs would rapidly become unavailable. This would mean that the majority of lighting fixtures in the majority of theatres - big theatres, small theatres, amateur theatres, colleges, schools, clubs, pubs, village halls - would immediately become obsolete. Fixtures that have given tireless service for years, sometimes for decades, with just a little regular maintenance and a new bulb every now and again would become yet more scrap metal and glass.

High-quality LED lighting units, which have made their way onto the market in recent years would also be banned under the proposals. 

The entertainment industry will have almost no tools whatsoever with which to light plays, musicals or concerts.

Even if it was within the possibilities of physics to create a lighting unit that was capable of meeting these proposals, it would be completely unreachable in a financial sense. It would require the immediate overhaul of infrastructure and stock  of almost every venue in Europe!
For larger venues, this would be both hard to budget for and impossible to implement within the next two years. For smaller venues, it would be ruinous. They would, quite literally, go dark.

We are not against conserving the world’s precious resources and we can only applaud what is otherwise, in our view, a laudable proposal. However stage lighting is not a big user of power: the lighting is only on for the relatively short duration of a performance and there are a relatively small number of performances per week; all of the lights in the rig are rarely, if ever, on at the same time, and because those lights that are on are rarely turned up to full. Several studies in recent years have shown that stage lighting typically accounts for less than 5% of a theatre’s total energy consumption.

We strongly request that specialist entertainment lighting equipment and light bulbs be exempt from these proposed regulations and from any future legislation which has the potential to directly impact the access to and availability of this equipment.