Development of a national strategy for disposal of lamps containing mercury: background

Environmental releases from lamps containing mercury

Mercury and its compounds are listed on Schedule 1 of the Canadian Environmental Protection Act, 1999 (CEPA) and are toxic to both human health and the environment.Footnote 2  In the environment, mercury can cycle between air, water, land, and living things, and can be transported over long distances in the atmosphere. In 2015, Canada emitted approximately 4.4 tonnes of mercury to airFootnote 3  and 121 kilograms to water,Footnote 4  while an estimated 115 tonnes of mercury are deposited in Canada every year from sources around the world.Footnote 5

Emissions from products containing mercury account for approximately 5% of total global anthropogenic releases.Footnote 6  Emissions of mercury from lamps occur at end-of-life if lamps are improperly disposed or recycled (i.e. landfilled or incinerated). In 2001, the Canadian Council of Ministers of the Environment (CCME) estimated that 1150 kg of mercury from lamps was disposed in Canadian landfills each year.Footnote 7  Due to significant reductions in the mercury content of lamps and the implementation of recycling programs since 2001 (see “Overview of Current End-of-Life Management for Lamps Containing Mercury in Canada” below), this has been reduced to  between 250 to 400 kg, based on currently available sales and end-of-life collection data. The range of this estimate is broad due to a lack of currently available information on end-of-life management.

Once these lamps are landfilled, mercury can enter the environment as vapour and in leachate, where small amounts can cause adverse effects. The Canadian water quality guideline for the protection of aquatic life for mercury in freshwater is 26 nanograms/litre.Footnote 8  To put this in perspective, an Olympic size swimming pool, consisting of 2.5 million litres, would exceed this guideline if 65 mg of mercury were dissolved in it, an amount that can often be found in a single Canadian household.

Improper disposal of lamps containing mercury represents a potential source of human exposure to mercury, which can cause adverse health effects at very low levels.Footnote 9  Consumers and workers involved in end-of-life management may not be aware of the presence of mercury in these lamps, routes of potential exposure (primarily inhalation), or the best practices for handling and cleaning up broken lamps.

Categories and uses of lamps containing mercury in Canada

A number of lamp categories contain mercury as part of their essential function. The most common types are linear fluorescent lamps (LFLs; also known as straight fluorescent lamps) and compact fluorescent lamps (CFLs) (Figure 1). LFLs are typically used in institutional and commercial buildings, while CFLs are more commonly used for residential lighting. Other mercury-containing lamp types include high intensity discharge (HID) lamps for street and stadium lighting, neon lamps for signs, cold-cathode fluorescent lamps for backlighting in electronics, and a few other specialty lamps. During the operational lifetime of a fluorescent lamp, the elemental (liquid) mercury within the lamp gradually becomes converted to solid compounds (mainly mercuric oxide) and concentrates in the phosphor powder that coats the glass.Footnote 10  Not all lamps containing mercury contain a phosphor coating (e.g. HID lamps, UV lights for tanning beds) and therefore these lamps may be more likely to contain elemental mercury at end-of-life.Footnote 11

Figure 1: Common types of lamps containing mercury

In 2001, the CCME published the Canada-wide Standard for Mercury-containing Lamps, which called for an 80% reduction in the average content of mercury in all mercury-containing lamps sold in Canada by 2010, from a 1990 baseline (43 mg).Footnote 7  By 2006, this target was achieved with an 81.6% reduction in mercury content for an average of 7.9 mg per lamp.Footnote 12  In 2016, the average mercury content in imported and manufactured lamps for general lighting purposes was 5.7 mg per lamp based on data collected under the Products Containing Mercury Regulations’ first reporting period (current as of September 13, 2017). The averages were calculated using data for CFLs, LFLs, and HID lamps for general lighting purposes.

The Products Containing Mercury Regulations under CEPA, in force since 2015, prohibit the import and manufacture of products containing mercury or any of its compounds, with some exemptions for essential products which have no technically or economically viable alternatives. In the case of lamps, rather than introducing a prohibition, the Regulations limit the amount of mercury contained in fluorescent and other types of lamps (Figure 1). The Regulations also require reporting on import and manufacturing of mercury-containing products every three years in order to monitor the trend in reduction of mercury in products in Canada, and that these products be labelled to inform consumers about the presence of mercury, safe handling procedures, and options for end-of-life management.Footnote 13

According to data received as part of the Products Containing Mercury Regulations’ first reporting period in 2016, the average mercury content in lamps for general lighting purposes imported or manufactured in Canada was around: 2 to 3 mg/lamp for CFLs; 2.5 to 4 mg/lamp for smaller-diameter T5 and T8 4-foot LFLs (the number after T indicates the diameter of the lamp in eighths of an inch); and 6 to 8.5 mg/lamp for larger-diameter T12 LFLs. For HID and specialty lamps, the mercury content varies widely based on design and wattage.

The Energy Efficiency Regulations, 2016 (under the Energy Efficiency Act) establish energy efficiency standards for a wide range of energy-using products, with the objective of eliminating the least energy-efficient products from the Canadian market.Footnote 14   For the last decade, the replacement of incandescent lightbulbs with CFLs has been promoted as requirements under these Regulations have become increasingly stringent. Given the past trends in lighting efficiency improvements, in the next ten years these regulations may lead to phase-outs of sales of many lamps containing mercury in favour of alternatives (e.g. light-emitting diodes (LED)). However, given their long lifetimes, existing stocks, and the unquantifie d amount of replacement lamps already purchased, it may be decades before some lamps containing mercury reach end-of-life. In addition, some specialty lamps currently have no mercury-free alternative and will remain in use for the foreseeable future.

Sales of mercury containing lamps and replacement options

CFL sales peaked in Canada in 2007 at approximately 70 million and have since declined significantly as LEDs have become more common for A-type (lightbulb-type) lighting (Figure 2).Footnote 12 Footnote Footnote 15  LEDs are now cost-competitive with CFLs, as A-line LED prices have declined by an average of approximately 30% per year from 2012-2016, and they offer a longer useful life.Footnote 12 Footnote   Due to this trend, at least one major lamp manufacturer has discontinued production of CFLs.Footnote 16 Footnote   On February 1st, 2018, ECCC released a consultation document and is beginning consultations on proposed amendments to the Products Containing Mercury Regulations, which include a proposed ban on the manufacture or import into Canada of CFLs for general lighting purposes starting in 2023.Footnote 17

LFLs, on the other hand, have until recently lacked a viable mercury-free replacement (e.g. linear LEDs or other LED fixtures), and replacing these lamps with LEDs is more complex and costly than replacing CFLs. Therefore, sales of LFLs have only started declining in recent years. Sales of LFLs in Canada declined an average of 8.7% per year from 2012 to 2016, and one major manufacturer has reported sales are currently declining by 15-20% per year directly in favour of LEDs. Sales of linear LEDs have only been tracked by the lamp industry association Electro-Federation Canada since 2016, when roughly 8 million were sold, compared to 26 million LFLs.Footnote 18  In the U.S., linear LEDs accounted for 21.7% of sales in the period from April to June 2017.Footnote 19

Figure 2: Sales of compact fluorescent lamps (CFL), linear fluorescent lamps (LFL), and light-emitting diode (LED) lamps in Canada, 1999 to 2017

Comparison of lamp sales in Canada by type, from 1999 to 2017.  Text version below.
Long description
Figure 2: Sales of compact fluorescent lamps, linear fluorescent lamps, and light-emitting diode lamps in Canada, 1999 to 2017, in millions
Type of lamp 1999 2000 2001 2002 2003 2004
2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017
Linear fluorescent lamp 57
52 52 52 47 43 43 43 45 45 46 45 45 38 39 36 33 28 24
Compact fluorescent lamp 4.2
4.4 5.3 6.5 9.3 16 45 41 74 51 47 43 23 20 22 22 18 14 8.4
Light emitting diode ND
ND ND ND ND ND ND ND ND ND ND 1.1 3.0 5.4 8.8 17 30 58 86

Source: Electro-Federation Canada

ND = No data

In 2016, estimated LED sales in Canada outpaced all other lamp types for the first time (Figure 2). The United States (U.S.) Department of Energy estimated in 2016 that the market penetration of LEDs in the U.S. lighting market will increase from 6% in 2015, to 30% by 2020, 59% by 2025, and 78% by 2030.Footnote 20  Given recent trends, the Canadian market is expected to move in a parallel course, however, recent evidence suggests the speed of this market transition was underestimated. Outdoor lighting is amongst the fastest transitioning sectors as approximately 30% of the 2.7 million streetlights in Canada have been or are committed to being replaced by LEDs.Footnote 21

Organic light emitting diodes (OLED) are a more recent technology in the lighting market. They are currently less efficient, significantly more expensive, and are mainly limited to flat-screen devices, though some lamps are currently sold in Canada.

Overview of current end-of-life management for lamps containing mercury in Canada

Provincial, territorial, federal and municipal governments have taken a number of actions in recent years to address the end-of-life management of lamps containing mercury, and some private sector companies collect these lamps.

  • International
    • Basel convention on Hazardous Waste
    • Minamata Convention on Mercury
  • Federal
    • Canadian Environmental Protection Act, 1999
    • Products Containing Mercury Regulations
    • Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations
    • Code of practice for the environmentally sound management of end-of-life lamps containing mercury
    • Energy Efficiency Regulations
  • Provincial
    • Extended producer responsibility (BC, MB, QC, and PE)
    • Industry-led voluntary stewardship program (NS)
    • Voluntary stewardship program for large volume generators (ON)
  • Municipal
    • Administration of household hazardous waste management programs
    • Landfill disposal bans
    • Household hazardous waste events
  • Private sector
    • Voluntary return-to-return programs
    • Lamp processor pick-up and courier services
    • Recycling company services

In 2009, the CCME targeted lamps containing mercury in the Canada-wide Action Plan for Extended Producer Responsibility (CAP-EPR).Footnote 22  Extended producer responsibility (EPR) shifts the cost of end-of-life management for selected products from municipalities to producers, who pass the cost to consumers. Jurisdictions committed to work towards the development of EPR framework legislation and/or regulations and to promote a harmonized approach across Canada. Since the adoption of CAP-EPR, there has been a significant increase in the number of product categories covered by legislated EPR programs across jurisdictions, such as electronics and electrical equipment. These programs require the producers, or the stewardship organization running the program on their behalf, to service all areas of the province, thus providing important household hazardous waste services to remote areas where options were previously limited.

Additionally, the territories have made important strides towards exploring opportunities for EPR and product stewardship in Canada’s North, and some partnerships have developed between territories and nearby provinces for targeted products.

Prince Edward Island, Quebec, Manitoba and British Columbia have legislated mandatory EPR programs for lamps containing mercury. Product Care Association manages these EPR programs under the brands LightRecycle (in PE, MB, and BC) and RecycFluo (in Quebec). Provincial rates of diversion (the capture rate) and the types of lamps covered by legislation vary (Table 1).Footnote 23 Footnote 24 The BC LightRecycle program is the most comprehensive in that it accepts all lamp types as well as fixtures and ballasts.

Ontario has announced it is planning to introduce EPR regulations for lamps containing mercury within the next few years,Footnote 25 and Saskatchewan is currently consulting on the development of household hazardous waste (including lamps containing mercury) product stewardship and recycling regulations.Footnote 26

A stewardship program has been implemented in Nova Scotia (Table 1). Nova Scotia’s mercury collection program is funded through electricity utility Nova Scotia Power, administered by the province’s energy efficiency utility EfficiencyOne, and delivered in partnership with Scout Environmental. The program offers free pick-ups and drop-offs of CFLs, LFLs, HID lamps, and other products containing mercury for residents and businesses.Footnote 27 The province provided an incentive to support the program’s development through its Air Quality Regulations, which allow a generator of mercury emissions to earn emissions credits through diversion of products containing mercury from landfill.Footnote 28 The regulations allow the program to exist until the end of 2024. It is the only known program in Canada that takes back any product containing mercury and even elemental mercury.

“Take Back the Light” is a national voluntary program established by the Recycling Council of Ontario for matching up non-residential lamp purchasers with sellers who will collect the lamps at end-of-life (Table 1). Users of the service register free of charge while lamp distributors are charged a fee based on gross sales. The program has collected over 26 million lamps since its launch in 2008.Footnote 29 The program has stringent requirements for processors, such as the stipulation that all mercury be recovered from the lamp components and no mercury should be sent to landfill.

Table 1: Stewardship programs for lamps containing mercury in Canada

Province

Initiative

Types of lamps

Capture rate target (2016)

Capture rate (2016)

 Sectors

British Columbia

Legislated EPR

All lamps, fixtures, and

ballasts

LFL: 34-62%

CFL: 36-62%

LFL: 42%

CFL: 51%

All sectors

Manitoba

Legislated EPR

LFL and CFL

40% of all lamps

LFL: 150%*

CFL: 35%

Residential only

Ontario

Voluntary stewardship

Legislated EPR planned

CFL, LFL, HID

N/A

Unknown

Non-residential only

Quebec

Legislated EPR

All lamps containing

mercury

LFL: 40%

CFL: 30%

HID: 40%

LFL: 40%,

CFL: 8%

HID: 32%

All sectors

Nova Scotia

Stewardship (industry-led)

CFL, LFL, HID

Unknown / No target

Unknown

All sectors

Prince Edward Island

Legislated EPR

LFL, CFL, HID, LED

Unknown / No target yet

13% of total lamps

All sectors

 * Note: capture rates exceeding 100% indicate greater than expected returns and/or non-residential users taking advantage of the residential program

Many municipalities offer annual or more frequent household hazardous waste collection days. These programs can be particularly effective for communities where residents do not have easy access to collection sites. Some municipalities may collect bulbs year-round (e.g. at community centres) and may have contracts in place to consolidate and send for processing. Municipalities may also play a role in promoting lamp recycling programs or providing information on collection sites for lamps on municipal web sites. Some municipal and private landfills will refuse large volumes of lamps whether or not a municipal ban is in place, which necessitates industry finding environmentally sound solutions.

Some retail stores that sell lamps voluntarily take back certain residential lamps free of charge in provinces without mandatory EPR programs as part of corporate product stewardship policy. According to company websites, RONA stores generally accept all types of lamps containing mercury, IKEA and Lowe’s accept CFLs only, and London Drugs takes back any product they sell, including any lamps and their packaging. Smaller retailers may also participate in recycling programs.

Other private sector companies offer end-of-life lamp collection services. These include lamp processors and companies that offer waste management solutions (e.g. containers and pickup service) to the industrial, commercial and institutional (ICI) sectors . Some lamp processors offer a courier service, where sturdy boxes are sent out to be filled with appropriately-sized lamps, with pre-paid shipping back to the processor included in the price of the box. Some lamp processors also attend household hazardous waste collection events.

In February 2017, ECCC published the Code of Practice for the Environmentally Sound Management of End-of-Life Lamps Containing Mercury (the Code of Practice) to complement provincial, territorial and other initiatives.Footnote 30  This voluntary instrument includes best practices for collection, storage, transport, processing, and disposal of lamps containing mercury at end-of-life, as well as guidance specific to northern and remote areas, where access to recycling and disposal facilities is limited, and additional information such as guidance for safely cleaning up broken lamps. A National Strategy may seek to follow-up on this publication by measuring awareness and implementation of the Code of Practice by targeted governments and stakeholders.

In addition, with ratification of the Minamata Convention in April 2017, Canada has obligations and reporting requirements through the entire life-cycle of mercury, including waste. Development of a National Strategy for lamps containing mercury and reporting on implementation every 5 years will contribute to Canada’s on-going commitment to the Convention, including on managing mercury waste in an environmentally sound manner, and on providing information for Canada’s national report. Canada is also Party to the Basel Convention, which sets requirements for the transboundary movement of hazardous wastes and hazardous recyclable materials including lamps containing mercury. Canada complies with the Convention through the Export and Import of Hazardous Waste and Hazardous Recyclable Material Regulations.Footnote 31 

Key challenges for end-of-life management 

There is currently no economic incentive for the environmentally sound end-of-life management of lamps containing mercury. These lamps are inconvenient to store and transport as they are fragile, hazardous if broken, and highly distributed across the country. From a recycling perspective, they are high cost relative to the value of their recovered (recycled) components and they contain hazardous material which requires special equipment and expertise to manage.

A key challenge is the need to increase diversion from the residential sector, which is the primary user of CFLs. According to the U.S. Department of Energy, in 2014 CFLs were the most-used lamp type in the residential sector, representing about half of all A-type lamps.Footnote 32  In 2009, 56% of Canadians reported disposing CFLs with their regular waste;Footnote 33  capture rates have since improved in some jurisdictions due to the provincial, municipal and other programs that are now in place. However, in 2015, 44% of Canadians still reported disposing CFLs with their regular waste, and some provincial disposal rates have remained static.Footnote 34  A survey of households in Maine identified two main factors to increase diversion of CFLs:

  • increasing easy access to and comprehensiveness of recycling information, and 
  • increasing the convenience of collection.Footnote 35 

Increasing diversion from the ICI sector and the construction, renovation, and demolition (CRD) sectors is a different challenge as these users generate larger volumes of lamps. It may be more difficult for these sectors to dispose of large volumes at landfill, but if they do so their impact is proportionally much larger compared to the residential sector. The BC and PE EPR programs offer free collection for these sectors and in other provinces these sectors can contract a waste management company to pick up spent lamps, however environmentally sound disposal then depends on the latter company’s practices. Additional information is needed to better assess the capture rates from the ICI and CRD sectors.

Under EPR programs, producers are responsible for physical, financial, and informative aspects of end-of-life management. Producer Responsibility Organizations track and report on the amount of lamps collected and their disposal. EPR and voluntary programs have shown variable rates of success by province and by lamp type, with some achieving greater than 100% capture rates (more lamps collected than were expected to have reached end-of-life) and others capturing less than 15% of available lamps. In the absence of EPR, jurisdictions do not have practical access to this information, so the capture rates of lamps containing mercury are not known for most jurisdictions or, as a result, for Canada as a whole. However, estimates could be made based on the number of lamps received and processed by lamp processors.

In provinces with EPR for lamps containing mercury, Producer Responsibility Organizations will soon or are already facing a decline in sales of lamps containing mercury, which reduces the funds available for operating the EPR program (generated at point-of-sale).Footnote 29  This problem may be mitigated by including LEDs in the EPR program, as British Columbia and Prince Edward Island do, but it is unknown if funds will remain sufficient to maintain capture rates, let alone increase them.

Northern, remote and Indigenous communities face unique challenges in end-of-life management of lamps containing mercury. These challenges can include, but are not limited to: limited access to supplies and training for safe end-of-life management, limited or inadequate storage facilities, high cost to transport to processing facilities (particularly when the community has no road access), and a lack of incentives for private industry to develop recycling infrastructure.

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