Creativity Works! is a leading European coalition of the cultural and creative sectors. Our coalition represents writers, screenwriters, video game developers, broadcasters, book publishers and retailers, cinema operators, sports organisers, picture agencies, music and film/TV producers, publishers and distributors.

We strongly support the European Commission’s efforts to reduce carbon emissions.  However, the proposed revisions of the Directive 2009/125/EC will have negative consequences in all areas of entertainment lighting and a severely damaging effect on film and TV production across Europe.

Access to the suitable light sources is of paramount importance for the cultural and creative industries. For this reason, an exception is provided in Article 3 of Regulation 1194/2012 for “special purpose products”, as defined under Article 2.4 of the same regulation.

Our sectors now face a serious issue – the draft rules would leave us without many of the light sources we rely upon, and with no alternatives available on the market that have the same lighting quality and features essential for film and TV production. In addition, the traditional lighting products currently in use are very durable and banning them, from an ecological perspective, is unlikely to bring the desired benefits.

In this context, Creativity Works! would like to express its support for the amendments set out in the attached joint industry position paper on the envisaged Implementing Regulation of Directive 2009/125/EC of the European Parliament and of the Council with regard to Eco-design requirements for light sources and separate control gears.

We respectfully urge the European Commission to further analyse and take into account the suggestions which have been developed together with a wide industry coalition across different sectors which will be deeply impacted by the draft Regulation as it currently stands.

The joint position paper proposes the following improvements in order for Europe’s creative industries to continue to function smoothly:

• Exemption from Standby Power mode and Networked Stand-by Power mode for stage and film and TV studio lighting;
• Exemption for White Light Sources for specific needs;
• Slight modification of the range of “Green wavelength” for colour tuneable sources;

A small number of additional and critical exemptions for specific lamp bases for use on stage and in film and TV studios.

With this in mind, Creativity Works! urges the European Commission to ensure that the above-mentioned exemption is included in the upcoming Implementing Regulation. The exemption ensures that creative industries can continue to produce quality content under the best conditions, while at the same time allowing sufficient time for the development of technology that is required to meet the conformity criteria.