HQI and halogen in floodlighting: what really applies to the phase-out

The RoHS Directive (2011/65/EU) restricts mercury and other substances in equipment newly placed on the market. Lamps containing mercury may only be placed on the market as long as an exemption applies.

The Ecodesign Regulation (EU) 2019/2020 has applied since 1 September 2021 and sets minimum values for luminous efficacy. It covers light sources between 60 and 82,000 lm.

RoHS exemption 4(e) for mercury in metal halide lamps runs until 24 February 2027 as things stand. The industry association LightingEurope applied in August 2025 for a five-year extension.

The date is therefore not a certain end: under Article 5 of the Directive, an exemption remains valid until the Commission has decided on the application. If it rejects it, a transition period of 12 to 18 months still applies according to LightingEurope.

For lamps up to 82,000 lm, the Ecodesign Regulation also applies: depending on the design, it gives threshold values of around 79 to 85 lm/W for metal halide lamps.

For high-pressure sodium lamps, exemption 4(c) also applies until 24 February 2027; an extension of three years has been requested. No extension is being requested for exemption 4(b), sodium lamps with improved colour rendering.

According to the industry association licht.de, high-pressure mercury vapour lamps (HQL) have not been allowed to be placed on the market since 2015.

According to licht.de, linear high-voltage halogen lamps with an R7s cap and more than 2,700 lm have not been permitted since 1 September 2021. The regulation now only sets its own thresholds for R7s up to 2,700 lm. The regulation does not name a separate exemption for floodlighting.

Yes. The rules apply to placing products on the market, not to operation. According to licht.de, remaining stock continues to be sold, and lamps that have already been bought may continue to be used.

The problem is more likely to be supply: if the right lamp or a spare part is no longer available, the system stops working. The city of Landsberg am Lech found this with its 1976 system: spare parts could no longer be obtained in the medium term, even online.

If you only react when the system fails, you have little room to manoeuvre. A funded retrofit needs lead time, because contracts may only be awarded after approval. It is therefore worth clarifying early:

• Which lamp types and ratings are installed?
• How many spare lamps and ballasts are still in stock?
• Can the masts carry new floodlights?
• Which funding fits, and how long does it take?

A pure lamp replacement is not funded under the Kommunalrichtlinie. What is funded there is the luminaire head including control, that is, replacing the floodlight.