Study to assess socio-economic impact of substitution of certain mercury-based lamps currently benefitting of RoHS 2 exemptions in Annex III

Towards the end of 2014, the EU Commission started receiving applications for the renewal of various exemptions listed in Annex III of the Directive. A large number of exemptions that had been listed in the Directive annex at the time that the RoHS 2 recast came into force were to become due for expiration in July 2016. In line with the Directive stipulations, stakeholders interested in the renewal of such exemptions had begun submitting requests for their renewal, many of which were related to the use of mercury in lamps. The evaluation of the requests was carried out by Oeko-Institut in 2015 and 2016 and a report including the evaluations of each of the requested exemptions was published in June 2016, providing recommendations as to the fate of each of the exemptions. In some cases an amendment of exemptions or a revoke was recommended. The lighting industry responded to the report, claiming that the withdrawal of the exemptions recommended for revoke would lead to extreme socio-economic costs for industry and subsequently for the European Union, among others in light of loss of employment opportunities, in light of the early closing of manufacturing facilities and in light of high investments in the conversion of existing luminaires or the purchase of new ones where the existing ones were not compatible with available LED substitutes. Against this background, the European Commission requested technical and scientific support in the preparation of a detailed evaluation of the socio-economic impact of early substitution of mercury in certain lamps. Among others, the study looked into the socio-economic impacts of lamp substitution under different options, in terms of impacts on employment, possible costs for various sectors related to lamp substitution, impacts on waste and impacts on the amount of mercury to be placed on the EU market.