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Incandescent Bulbs Phase-Out (GLS) Programme: Are Malaysians Short-Changed?




A report entitled 'Switch It Right' has been published by AWER to highlight the issues surrounding the incandescent bulbs (GLS) phase-out programme in Malaysia. The report is available in Bahasa Malaysia, English and Mandarin at www.awer.org.my and www.click.org.my. An extended version of the report is available only at www.click.org.my as Special Report. The Special Report consists of testing result, rating and label of tested CFL specimens.

Due to the nature of its operation, GLS converts electrical energy into light and heat energy. The total energy used in generating light is far lesser compared to generating heat. This makes GLS very inefficient. To justify GLS phase out, Energy Commission (ST) estimates that about 20% of the lamps used in Malaysia are of the incandescent type (GLS) which is 15 million GLS sold annually. They estimated that annual energy savings is about 1,074 GWh and a saving of RM336 million in electricity consumption expenditure by consumers. However, based on statistics AWER obtained from Department of Statistics, annual average of GLS bulbs consumed is only around 2.4 million bulbs between year 2007 - 2011. This is only around 16% of what is claimed by ST. Have the industries duped ST or ST had made a serious miscalculation?

The delay in putting up proper rules and regulations in phasing-out GLS has also allowed many unwanted issues mushrooming quickly in Malaysia. Let us see the challenges in phasing-out GLS.


Challenge 1: Impact to Supply and Demand of Lighting Products
A phase-out process will remove inefficient products and replace it with suitable and efficient products. Compact Fluorescent Lamp (CFL) has been identified as a suitable candidate to replace GLS. In addition to that, Light Emitting Diode (LED) lights are also slowly taking up market share. A peak demand occurs due to shift from GLS to other types of lighting products by regulatory needs.

This calls for stringent regulations to be put in place in Malaysia to ensure product's quality is also maintained. Lower quality of products will increase waste generation which defeats the primary purpose of phase-out programme that is environmental protection.

Challenge 2: Misleading Phase-out Programme Announcement
In Malaysia, the current phase-out programme announcement did not identify the function of other types of lighting products such as fluorescent tubes, halogen bulbs, and efficient incandescent bulbs (also known as improved halogen bulbs).

In this phase-out programme, only GLS is being phased-out and not fluorescent tubes. The fluorescent tubes are actually better for lighting in many spaces. Currently, this announcement has caused fluorescent tubes to be mistakenly neglected or misunderstood. Halogen bulbs are also being phased-out in developed nations. Due to this, the inefficient versions of halogen bulbs are emerging rapidly in Malaysian market simply because their existence in Malaysia is neither regulated nor blocked.

Therefore, communication to the public must be clear and educating. Confusing statements and jargons will leave the public perplexed and not knowing which way to move. This will also cause rejection from them or they will get tired of the so called "new" and "greener" solution policies.

Challenge 3: Doubtful Product Information
Information about a product is mainly published on the packaging of the product or addition leaflet which is placed inside the packaging. Unfortunately, various products have flocked the market and create confusion among users.

Based on our product sampling for CFL, some of the problems related to product information are as wrong information, fake energy label, no manufacturer’s details, wrong claims and doubtful health claims.

Challenge 4: Product Quality
Due to peaking demand for CFL worldwide, quality of products that meets the demand will always be an issue. In any production line, normal distribution is applied to ensure product quality is maintained in a preferable ‘bell curve’ that fits design specifications. In Malaysia, there have been many cases where ‘branded’ CFL do not even last a year in operation. Now, what guarantee the manufacturers can give to users to ensure quality of product is maintained while meeting the demand?

Challenge 5: Pricing of CFL is Vague
Retail price of CFL did not see much drop even after Malaysian government announced phase-out programme in year 2010. In this phase-out programme, the government is removing a huge market share of a cheaply priced competitor (GLS) to CFL by 2014. In addition to that, duty exemption benefits were also given for energy efficient lighting. Unfortunately, the price of these products has not reduced. On the other hand, the phase-out

programme announcement has also benefitted some CFL products that are sold as low as RM 3.00. The quality of these products is also questionable. Furthermore, some established brands of CFL have higher retail price in supermarket and hypermarket compared to lighting shops which offer almost half of the price. Now, are Malaysians being short-changed?

Challenge 6: Hazardous Waste Management
The mercury content in the fluorescent technology is nothing new. The CFL inherit the similar mercury content problem. Under the Environmental Quality Act 1974 (EQA), mercury in products and processes must be disposed safely as it is classified as one of the scheduled waste. Unfortunately, domestic users are not bound by this rule.

For example, if a domestic user disposes CFL into waste bin, it will be collected as garbage (solid waste). Once the waste collector collects the CFL from the waste bin, it becomes scheduled waste as business entities are regulated under EQA. Now, will the waste collection companies dispose the CFL via prescribed method or ‘close one eye’ and leave it to be buried in landfill? The Scheduled Waste (or also known as Hazardous Waste) management is vital to be put in place before full scale phase-out of GLS. Without proper waste management mechanism, shifting to CFL is not environmentally friendly as claimed.


Based on the findings via our study, the GLS phase-out needs more careful planning to prevent unwanted problems in Malaysia. The following recommendations from AWER will be forwarded to ST, KeTTHA and other relevant agencies. AWER will monitor the implementation of the recommendations as a Key Performance Index set by us for both ST and KeTTHA.

Recommendation 1: Standard, Testing and Labelling
Based on our consultation with ST, the regulations for GLS phase-out and CFL testing are still with the Attorney General's (AG) office. Delay in approving regulations or guidelines will only give serious negative impacts to the implementation of phase-out process which should fully take place by year 2014.

All lighting products sold in the market must be labelled uniformly to assist end users to be able to compare product functions easily. Currently, Malaysia does not have any such standard label in place.

Recommendation 2: In-Flow of Halogen Bulbs
Halogen bulbs are in the process of being phased-out by EU. The C class and D class (the class is based on EU energy efficiency labelling) halogen bulbs will be phased-out by year 2016. However, there is a sudden in flow of these bulbs in Malaysian market. In addition to that, the halogen bulbs that are in B class are still having technical problems. Based on AWER's study, we do not see this technology as a potential replacement for GLS as the core technology for emitting light is similar to GLS. We urge ST to prevent double phase-out attempts by banning halogen bulbs sales here with immediate effect.

Recommendation 3: Waste Management
Waste management of CFL is still in dark. The EQA via Environment Quality (Scheduled Waste) Regulation 2005 classify mercury waste as SW109. The disposal of CFL and the fluorescent tubes are not classified as E-Waste (Electronic Waste). They are currently being disposed directly to waste bins. In addition to that, any contamination to other type of normal waste with scheduled waste will need specific disposal. In other word, if a CFL breaks in a waste bin or waste collection lorry, the entire waste needs to be treated as part of scheduled waste. However, this is not practised in Malaysia and such a problem must be rectified before full implementation of GLS phase-out.

Recommendation 4: Assisting Financially Challenged Groups
The low income group are AWER's immediate concern. When they replace a GLS, they do not spend anything above RM 3.00. However, the purchasing cost of a CFL is way too expensive for them to make an immediate replacement. Based on some of our surveys with users that have already opted to CFL, the products they use sometimes do not even last 1 year of operation even though it is a branded product. If such a situation occurs, the replacement cost will deter many middle income groups as well. Therefore, quality of CFL must be addressed by ST immediately. A financial assistance mechanism must also be developed to assist this group to switch to CFL or other better lighting products.

Recommendation 5: Preventing Price Fixing and Profiteering
The phase-out of GLS is to remove high carbon footprint technology and replace it with lower carbon footprint technology such as CFL. Therefore, with reduction in market competition, the CFL price should be reduced. Unfortunately, this does not take place. AWER has purchased a genuine branded product in a location in Negeri Sembilan for RM 8.00 and the similar product is sold in few hypermarkets at a price that is above RM 16.00. Now, are consumers being short-changed?

In addition to that, the purchasing cost of house brands CFL that are carried by local hypermarkets are always cheaper than the branded CFL. Does this mean that the cheaper house brands are of worst quality compared to premium brands? Definitely this would not be the situation. It can only mean that there is element of cartel and profiteering. Therefore, AWER urges Malaysian Competition Commission (MyCC) to carry out an investigation on this matter. This would be the first Key Performance Index set by AWER for MyCC and they must release the investigation report by end of December 2012 for public knowledge.

Recommendation 6: Continuous Monitoring and Enforcement
Regulations that are supposed to be carried out have been delayed as it is still with the Attorney General's office (information during our meeting in fourth quarter of 2011). We urge ST to increase the speed of preparation of standard, labelling, regulations, guidelines, etc to assist in continuous monitoring and enforcement. AWER will continue to follow up

with ST on this matter to ensure our recommendations are implemented properly and the problems are rectified as soon as possible.

3.         CONCLUSION

In our study on the GLS phase-out programme, Energy Efficiency is the key component. However, it should not be at the expense of human health and environmental safety. Heavy metals are a concern to health and environmental degradation. Will we repeat the same mistakes recorded in history? Beginning in the 1920s, lead (Plumbum - a heavy metal) was added to petrol (gasoline) to improve its combustion. This has caused increase in lead poisoning that affects children the most with many permanent damages. It took humans almost 60 years to realise this.

We urge the relevant agencies in Malaysia to take heed of our findings in this report to ensure we SWITCH IT RIGHT from the first time.

Piarapakaran  S.
Association of Water and Energy Research Malaysia (AWER)

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