Proposed Lighting Regulations

March 15 2023

Department of Climate Change, Energy
The Environment and Water

Comments on the draft determinations on LED and incandescent lamps being released as part of the Greenhouse and Energy Minimum Standards Act 2012 (GEMS Act).

As the original proponent of Australia’s phase-out of inefficient incandescent globes, I am writing in support of the next key steps in this process – the proposed phase out of inefficient halogen lamps and the introduction of MEPS for LED lamps.

My expertise in the energy space

In addition to initiating and proposing the 3 year phaseout of incandescent globes to the Howard Government, I was the author of the energy efficiency books ‘EnergyCut’ and ‘EnergySmart Saver’. Funded by the Gillard and Abbott Federal Governments and the South Australian government, these books were the definitive guidebooks on energy efficiency for businesses and households.

I was also the host and producer of ‘Smart Money’ on Sky News Business Channel for which I wrote and presented 115 programmes on business sustainability and energy efficiency. For the past 4.5 years, I have been heading up the Australian side of the global ‘RE100' initiative which has over 112 major Australian and international businesses going 100% renewable with their Australian electricity use.

Why I support these changes

The original phase-out of inefficient incandescent lamps and the regulation of Minimum Energy Performance Standards for halogen and CFLs has already delivered significant energy savings to consumers. It has also reduced network demand and led to significant reductions in greenhouse gas emissions.

The financial savings resulting from these changes have also been very significant. It’s estimated that these moves have saved consumers and businesses billions of dollars in reduced electricity bills.

The proposed phase-out of halogen lamps offers a further opportunity for energy and greenhouse gas emissions savings, and significant reductions in energy bills.

A wide range of LED lighting alternatives are now available, so this step can be undertaken without significant upfront impact on households. Indeed households will benefit financially from these proposed measures. At a time of rising costs, potential savings in household energy bills will be an estimated $1.396 billion by 2030.

The introduction of MEPS for LED lamps is also important as it ensures that these alternative products deliver energy and emissions savings (through greater efficiency), while also providing at least an equivalent lighting service. 

The discussion paper correctly notes that product screening in Australia and elsewhere has identified a wide range of quality and performance across LEDs in the market. In the interests of consumers, a focus on improved quality and efficiency would provide far better outcomes for Australians.

It is therefore important that the proposed regulation is backed by well-resourced monitoring and compliance action to remove low performing products from the Australian market. In this area, particular attention needs to be given to companies that directly import poor quality cheaper lighting into Australia.

The proposed alignment of the regulation with EU regulation and international test standards will help to ensure that this proposal is delivered at a lower cost to industry and consumers. A failure to align with this EU regulation could lead to Australia becoming a dumping ground for low quality lighting products.

In addition to the current proposal I would recommend that the lighting market continue to be monitored for further opportunities for energy and emissions savings.  This includes:

- Further tightening of the efficacy levels for LED lamps as performance improves.

- Expansion of the LED MEPS to include commonly used integrated LED luminaires.

- A phase-out of fluorescent lamps that contain mercury. As mercury free LED alternatives are now available, this needs implementing at some point.

This letter also represents the views of DoSomething Foundation, of which I am the co-founder and Managing Director.

Yours sincerely,

Jon Dee
Australian of the Year 2010 (NSW)
Co-Founder and Managing Director
DoSomething Foundation