Consumer Council's Submission on the Restriction of Sale of
Energy-inefficient Incandescent Light Bulbs (November 2011)
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1. The Consumer Council (the Council)
is pleased to submit views to the Environment Bureau (EB) regarding
issues raised in the consultation document on Restriction of Sale
of Energy-inefficient Incandescent Light Bulbs (ILB) which are set
out in the following.
Whether Hong Kong should restrict the
supply of energy-inefficient ILB by mandatory scheme, voluntary
measures or leaving it to market forces
2. The Council supports launch of a
mandatory scheme to restrict the supply of energy-inefficient ILB,
since it would be difficult to achieve the desired effect by
voluntary measures or market forces.
3. The Council believes that by
restricting the supply of ILB, higher energy efficiency lamps will
come to be more widely used as replacement. This can produce saving
in electricity bills for general consumers and reduction of carbon
dioxide emissions from the community at large.
The types of ILB that should be
restricted if a mandatory scheme is introduced to restrict the
supply of ILB
4. The Council supports restricting the
supply of non-reflector type ILB by phases through legislation. The
Council agrees that 25 watt or above non-reflector type ILB, which
operates at a single phase electricity supply of nominal voltage of
220 volts, should be covered in the initial phase of the mandatory
scheme since many substitutes are available in the local
market.
Whether Hong Kong should adopt the
MEPS approach in phasing out ILB
5. The Council considers mandating
the minimum energy performance standards (MEPS) a viable approach
in phasing out ILB. The Council supports requiring importers or
manufacturers of ILB to submit to the EMSD product test reports and
updated information at reasonable intervals and recommends that
EMSD's register be closely monitored for effective
control.
6. To ensure that
the regulated products perform within the prescribed limits, the
Council suggests that EMSD conducts surveillance checks/tests to
see if the energy efficiency of ILB products are as
claimed.
7. The Council agrees that registered ILB
products should carry appropriate labelling to enable consumers to
identify them easily.
8. However, it may be difficult for
consumers to appreciate the difference between different types of
ILB, that is, registered ILB, excluded ILB (such as tungsten
halogen lamps), and non-regulated reflector type ILB.
9. The Council therefore calls for
an educational publicity drive to be launched well before
implementation of the scheme to raise awareness and understanding
of the general public.
Chemical Waste arising from spent
CFL
10. Upon implementation of the
proposed scheme, it can be foreseen that more consumers will switch
to use compact fluorescent lamps (CFL), which are commonly
available in the market. While the public at large will benefit
from the reduced power consumption in Hong Kong, the Council is
highly concerned that the capacity of the treatment facility at the
Chemical Waste Treatment Centre for the treatment of disposed CFL
may not be sufficient to cope with the increasing usage of CFL when
ILB is being phased out. Any improper disposal of the used CFL,
more particularly if chemical waste disposal capacity falls short
of demand, would increase the risk of environmental contamination.
It will be necessary for the government to ensure there is
corresponding expansion in the capacity of the treatment facility
at the Chemical Waste Treatment Centre to cope with increased CFL
dumping arising from restricting the supply of ILB.
11. Furthermore, if many CFLs are
handled like normal garbage, the mercury vapours might leak out and
it could pose potential health hazard to workers who process
rubbish. The potential health risks associated with mercury should
not be overlooked.
12. It will be to consumers' benefit
for EMSD to draw more CFL samples of listed MEELS models for
compliance monitoring test on their energy performance and promptly
de-register models with performance or life spans falling short of
the requirements under the Mandatory Energy Efficiency Labelling
Scheme.
13. The Council recommends that
sustainability assessment of CFL should take into account the
aspect of chemical waste treatment. Energy and resources consumed
in waste treatment and recycling should also be included in the
calculation of saving potentials or benefits of implementing the
scheme.
Replacement
Options
14. The Council calls for the
government to promote alternative forms of energy-efficient
lighting (for instance LED lamps) to enable consumers to make
informed choices as they switch away from ILB. Currently, LED lamps
are subject of a voluntary Energy Efficiency Labelling Scheme
launched in June 2011. The government may consider conducting
performance tests and quality assessment on LED lamps available on
the market to enable consumers to assess the costs and benefits of
using them as substitutes for ILB and CFL.
