Well the govmonks have done it again, banning the bulb.
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>formatting link
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> We use bulbs for electric heating and lighting, shall electric heaters
> be banned too. Ten months of the year we need supplemental
> heating and incandescense work well for much of that, otherwise
> we'll use florescent AND electric heaters.
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> We're stockpiling bulbs and designing a manufacturing system.
That would be illegal to sell.
Supporting electronics for CFL and LED bulbs generate heat also. Most manufacturers are aiming for high efficience (low heat ratio), but easy enough to do high heating bulbs. Nothing prevent you from selling low efficience (high heat) LED bulbs.