by the study team for the most optimistic forecast on on the forecast discussion as in Figure efficacy improvement and without 1. margin , where in the same document it is also mentioned (page 14) that the increase may freeze in near future due to market developments 4 Summary 16 Re-wiring for LED The re-wiring that can be necessary for Make the observation also for other tubes LED tubes in retrofit application is not retrofit applications. limited to LED tubes only but applies to other categories too. 4 Summary 18 Availability of retrofit It is correctly stated that not for all R7 Add references for retrofit issues for See figure 4 for R7 lamps adequate retrofit exist (due to other product categories. dimensions, spatial light distribution,…) This is also valid for other products, even for non-directional GLS and CFLi Table 17, 80, etc Different electricity Is it a sound ecodesign criterion to use Use a uniform electricity rate 4 18, 19, rates used per different electricity rate to compare etc technology technologies? 4 Table 27 101 9.5 W for CFLi Is this the ‘average’ wattage for CFLi? Use more realistic wattage and thus efficiency; with upward trend as LED replacement starts at lower wattages (see also last paragraph on page 100) 5 General Only one LED category Why is there only one general LED Split LED into subcategories, make category while the other categories comparisons for same Tc, luminous are split up? equivalence as per 244/2009 5 General Product characteristics Are figures based on actual measurements or catalogue data 5 Summary 6 Figure 1 LCC Results differ significantly from other Calibrate studies 5 Table 10 23 9.5 W for CFLi Is this the ‘average’ wattage for CFLi? Use more realistic wattage and thus efficiency; with upward trend as LED
by the study team for discussion as in Figure 1. the most optimistic forecast on efficacy improvement and without margin , where in the same document it is also mentioned (page 14) that the increase may freeze in near future due to market developments on the forecast 4 Summary 16 Re-wiring for LED tubes The re-wiring that can be necessary for LED tubes in retrofit application is not limited to LED tubes only but applies to other categories too. Make the observation also for other retrofit applications. 4 Summary 18 Availability of retrofit for R7 It is correctly stated that not for all R7 lamps adequate retrofit exist (due to dimensions, spatial light distribution,…) This is also valid for other products, even for non-directional GLS and CFLi Add references for retrofit issues for other product categories. See figure 4 4 Table 17, 18, 19, etc 80, etc Different electricity rates used per technology Is it a sound ecodesign criterion to use different electricity rate to compare technologies? Use a uniform electricity rate 4 Table 27 101 9.5 W for CFLi Is this the ‘average’ wattage for CFLi? Use more realistic wattage and thus efficiency; with upward trend as LED replacement starts at lower wattages (see also last paragraph on page 100) 5 General Only one LED category Why is there only one general LED category while the other categories are split up? Split LED into subcategories, make comparisons for same Tc, luminous equivalence as per 244/2009 5 General Product characteristics Are figures based on actual measurements or catalogue data 5 Summary 6 Figure 1 LCC Results differ significantly from other studies Calibrate 5 Table 10 23 9.5 W for CFLi Is this the ‘average’ wattage for CFLi? Use more realistic wattage and thus efficiency; with upward trend as LED
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