COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/53/EU on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment
Date: 2021-09-23
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: Community certification, EC conformity marking, European standard, harmonisation of standards, market approval, market supervision, quality label, quality standard, technical standard, telecommunications equipment

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 23.9.2021  SWD(2021) 245 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a Directive of the European Parliament and of the Council amending Directive 2014/53/EU on the harmonisation of the laws of the Member States relating to the making available on the market of radio equipment {COM(2021) 547 final} - {SEC(2021) 318 final} - {SWD(2021) 244 final} - {SWD(2021) 246 final}  
 
 
Table of Contents 

1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT................................................................ 1 

1.1.  Policy context .................................................................................................... 1 
1.2.  Legal context ..................................................................................................... 4 

2. 

PROBLEM DEFINITION ..................................................................................................................... 8 

2.1.  What are the problems? ..................................................................................... 8 
2.2.  What are the problem drivers? ......................................................................... 15 
2.3.  How will the problem evolve?......................................................................... 20 
Impact of COVID-19 ....................................................................................... 24 
2.4. 

3.  WHY SHOULD THE EU ACT? ......................................................................................................... 24 

3.1.  Legal basis ....................................................................................................... 24 
3.2.  Subsidiarity: Necessity of EU action ............................................................... 24 
3.3.  Subsidiarity: Added value of EU action .......................................................... 25 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................ 26 

4.1.  General objectives ........................................................................................... 26 
4.2.  Specific objectives ........................................................................................... 26 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? ..................................................................... 27 

5.1.  What is the baseline from which options are assessed? .................................. 29 
5.2.  Description of the policy options..................................................................... 30 
5.3.  Discarded options and measures ...................................................................... 30 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................ 33 

6.1.  Policy Option 0 – baseline scenario ................................................................ 35 
6.2.  Policy Option 1 – Harmonisation of the end-device connector ....................... 35 
6.3.  Policy Option 2 – Support of the relevant charging protocol on the end-

device and informing consumers about charging performance ....................... 39 
6.4.  Policy Option 3 – Unbundled solutions in addition to Option 2 ..................... 42 
6.5.  Policy Option 4 – Charging interoperability in addition to Option 1 .............. 46 
6.6.  Policy Option 5 – A common connector in addition to Option 3 .................... 47 

7.  HOW DO THE OPTIONS COMPARE? ............................................................................................. 50 

8. 

PREFERRED OPTION ....................................................................................................................... 53 

8.1.  Preferred policy option: option 5 with a broad scope ...................................... 53 
8.2.  REFIT (simplification and improved efficiency) ............................................ 56 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? .................................. 56 

ANNEX 1: PROCEDURAL INFORMATION ............................................................................................. 59 

1. 

LEAD DG, DECIDE PLANNING/CWP REFERENCES .................................................................. 59 

2.  ORGANISATION AND TIMING ...................................................................................................... 59 

3. 

4. 

CONSULTATION OF THE RSB ....................................................................................................... 59 

EVIDENCE, SOURCES AND QUALITY ......................................................................................... 61 

ANNEX 2: STAKEHOLDERS’ CONSULTATION .................................................................................... 63 

 
 
1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

INTRODUCTION ............................................................................................................................... 63 

INCEPTION IMPACT ASSESSMENT (2018-2019) ......................................................................... 63 

PUBLIC CONSULTATION (2019) .................................................................................................... 63 

CONSUMER SURVEY (2019) ........................................................................................................... 66 

CONSUMER SURVEY (2021) ........................................................................................................... 68 

STAKEHOLDER CONSULTATION (2020-2021) ............................................................................ 71 

TARGETED INTERVIEWS ............................................................................................................... 73 

EXPERT GROUP MEETING CONSULTATION (2020-2021) ........................................................ 73 

ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................... 74 

1. 

2. 

PRACTICAL IMPLICATIONS OF THE INITIATIVE ..................................................................... 74 

SUMMARY OF COSTS AND BENEFITS ........................................................................................ 75 

ANNEX 4: ANALYTICAL METHODS ...................................................................................................... 77 

1. 

2. 

3. 

ENVIRONMENTAL ASSUMPTIONS AND CALCULATIONS ..................................................... 77 

ECONOMIC ASSUMPTIONS AND CALCULATIONS .................................................................. 82 

SCOPE OF THE IMPACT ASSESSMENT AND ASSUMPTIONS .................................................. 98 

4.  OTHER ASSUMPTIONS ................................................................................................................. 103 

5. 

6. 

IMPACTS OF THE DIFFERENT MEASURES ............................................................................... 105 

IMPACTS OF THE AGGREGATED MEASURES ......................................................................... 108 

ANNEX 5: STATE-OF-PLAY OF CHARGING TECHNOLOGIES ........................................................ 112 

ANNEX 6: COHERENCY MAPPING – RELATED PIECES OF EU LAW ............................................ 128 

GLOSSARY ................................................................................................................................................ 133 

 
 
 
 
 
1. 

INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

1.1. 

Policy context 

This  Impact  Assessment  concerns  an  initiative  in  support  of  harmonised  charging  and 
unbundling for mobile phones and other similar devices. In particular, this initiative  aims 
to establish a common level of interoperability for chargers of mobile phones and similar 
devices  so  to  achieve  consumer  convenience  and  environmental  benefits  while  further 
incentivising the unbundling of charger from the radio equipment. For the purposes of this 
Impact  Assessment,  a  “charger”  is  intended  as  the  combination  of  an  External  Power 
Supply  (EPS1)  and  a  cable.  The  combination  of  an  EPS  and  a  pad2  is  intended  to  be  a 
“wireless charger” – see Annex 5 for a thorough explanation.  

In 2009 there were different charging technologies that applied to mobile phones and the 
level of fragmentation resulted in consumer inconvenience and generation of unnecessary 
waste.  In  order  to  mitigate  those  problems,  the  European  Commission  facilitated  a 
voluntary  agreement  on  the  “harmonisation  of  a  charging  capability  for  mobile  phones”, 
resulting  in  a  first  Memorandum  of  Understanding  (MoU)3  signed  by  major  phone 
industries.  The  signatories  agreed  to  develop  a  common  connector4  for  charging,  whose 
specifications were based on a specific standard5, and would allow full compatibility with 
mobile phones to be placed on the market. For those phones that did not have a micro USB 
type B interface6, an adaptor was allowed. At the international level, the initiative led to an 
alignment  to  the  MoU  almost  globally.  The  implementation  of  the  agreement  led  to  an 
effective reduction in charging solutions for mobile phones from 30 to only 3. 

However, the MoU also allowed for the use of proprietary charging interface, and one such 
solution  continued  to  be  used  (and  still is)  by  a  major  mobile  phone  manufacturer7,  who 
never aligned to the common connector mentioned above and therefore failing to allow full 
interoperability. At the same time, unbundling (i.e. the sale of device without a charger, or 
only  with  a  cable)  had  not  been  achieved  to  a  significant  extent,  with  only  a  handful  of 
companies offering such a possibility to consumers.  

The  MoU  was  renewed  twice  and  finally  expired  in  2014.  Since  the  expiration,  the 
Commission has put much effort to find consensus on a new MoU that would complete the 
harmonisation of the charging interfaces. As a result, another MoU was proposed/signed in 

1 Device converting alternating current (AC) power input from the mains into direct current (DC) to power a 
product as defined in Regulation (EU) 2019/1782 on eco-design 
2 a combination of circuitry and coil that allow wireless power transfer 
3 https://ec.europa.eu/docsroom/documents/2417/attachments/1/translations/en/renditions/native 
https://ec.europa.eu/docsroom/documents/2417/attachments/1/translations/en/renditions/native  
4 Electrical termination which is built according to a specific blueprint/technical drawing and interface 
5 USB 2.0 micro-B, see Annex 5 for the details of this technology 
6 For a complete explanation of micro USB type B, see Annex 5 
7 namely Apple’s Lightning 

1 

 
                                                           
March  20188,  which  covered  only  wired  charging  solutions,  and  considered  (as  therein 
written) “the following cable assemblies to be compliant:  

  a cable assembly that is terminated on both ends with a USB Type-C9 plug;  
  a cable assembly that is terminated on one end with a USB Type-C plug and has a 
vendor-specific  connect  means  (hardwired/captive  or  custom  detachable)  on  the 
opposite end; and  

  a cable assembly that sources power to a USB Type-C connector from a USB Type-

A10 connector”. 

Already the preliminary drafts of this MoU were deemed not satisfactory11 in view of the 
policy  objectives  of  the  Union  as  they  neither  resolved  the  remaining  interoperability 
issues,  nor  addressed  future  possible  evolutions  (wireless  or  fast  charging),  nor  extended 
the original scope of the initiative to harmonise charging solutions for other devices similar 
to mobile phones that would further strengthen the consumer convenience. Also a number 
of Members of the European Parliament (MEPs) expressed their disappointment with the 
MoU12,  which  in  their  view  “neither  has  a  scope  that  extends  beyond  smartphones,  nor 
solves the fragmentation  in  that sector,  showing  the limitations  of  voluntary approaches, 
where vetoes of strong market players influence the outcome and lead to an unsatisfactory 
approach  also  in  terms  of  environmental  policy  objectives”.  The  European  Parliament 
stressed in its Resolution in January 202013 the need to increase consumer convenience and 
reduce e-waste by means of actions to harmonise chargers. For the purposes of this Impact 
Assessment,  e-waste  is  intended  as  waste  from  electronic  and  electrical  equipment.  Also 
consumers  and  their  associations,  have  stressed  the  need  to  take  action14  in  order  to 
address 
issues  (connector  and  charging 
incompatibility 
communication  protocol)  and  head  towards  a  solution  that  returns  benefits  for  the 
environment.  

the  remaining  charging 

As  a  result,  the  Commission  launched  studies15  16  in  2019  and  2020  to  assess  impacts  of 
possible  options  with  the  following  objectives  on  the  end-device  side:  (i)  remove 
fragmentation,  addressing  the  consumer  convenience,  (ii)  reduce  e-waste,  and  (iii)  be 
forward  looking,  monitoring  the  state  of  play  of  future  charging  technologies  (e.g. 
wireless), aiming to both preventing fragmentation yet without hampering innovation.  

8 https://www.digitaleurope.org/resources/memorandum-of-understanding-on-the-future-common-charging-
solution-for-smartphones/  
9 See Annex 5 for explanations on this technology 
10 See Annex 5 for explanations on this technology 
11 for instance see the reply to the last proposed draft in Ares(2018)242745 
12https://www.eppgroup.eu/sites/default/files/pr_attachment/Letter%20to%20Commissioner%20Bienkowska
%20PDF.pdf  
13 https://www.europarl.europa.eu/doceo/document/TA-9-2020-0024_EN.html  
14 https://www.anec.eu/images/Publications/position-papers/Digital/ANEC-DIGITAL-2019-G-008final.pdf  
15 https://op.europa.eu/en/web/eu-law-and-publications/publication-detail/-/publication/c6fadfea-4641-11ea-
b81b-01aa75ed71a1  
16 https://data.europa.eu/doi/10.2873/788086 and https://data.europa.eu/doi/10.2873/537546 

2 

 
                                                           
This initiative on the common charging and unbundling of mobile phones and similar radio 
equipment,  hereinafter  referred  to  as  “this  initiative”,  was  included  in  the  Commission 
Work  Programme  2020  for  Q3  202017.  This  initiative  focuses  on  requirements  on  end-
devices, for which the Radio Equipment Directive apply (see section 1.2). Possible future 
requirements  on  EPS  would  be  based  on  a  different  complementing  initiative,  which  has 
been planned (see Annex 6). These two complementary initiatives covering both sides of a 
cable would contribute to achieving interoperability between the devices and the chargers.  

Unfortunately, the Covid-19 worldwide pandemic delayed the schedule of this initiative. It 
was  then  rescheduled  for  Q1  2021  in  the  adjusted  Commission  Work  Programme  202018 
and  linked  to  the  EU’s  priority  ‘An  economy  that  works  for  people’,  as  it  promotes 
interoperability in support of consumers’ convenience, and to achieving the EU goal of a 
more  sustainable  economy.  It  also  aims  to  contribute  to  the  implementation  of  the 
European  Green  Deal,  which  includes  commitment  to  mobilise  industry  for  a  clean  and 
circular economy, through a ‘sustainable products policy’ that support the circular design 
of products. It will prioritise reducing and reusing materials before recycling them and will 
foster  new  business  models  and  set  minimum  requirements  to  prevent  environmentally 
harmful products from being placed on the EU market. Finally, this initiative is also linked 
to the EU’s priority ‘A Europe Fit for the Digital Age’, under the objective of Digital for 
consumers. The EU’s digital strategy aims to make this transformation work for people and 
businesses by giving them more choice, lowering the prices, giving them less exposure to 
illegal  content,  and  ensuring  a  better  protection  of  fundamental  rights,  while  helping  to 
achieve its target of a climate-neutral Europe by 2050. The Commission is determined to 
make this Europe's “Digital Decade”. Europe must now strengthen its digital sovereignty 
and  set  standards,  rather  than  following  those  of  others  –  with  a  clear  focus  on  data, 
technology, and infrastructure. 

Finally  it  is  noted  that  there  is  a  parallel  initiative  also  on  Energy  labelling  of  mobile 
phones  and  tablets19.  This  initiative  aims  to  provide  a  clear  and  simple  indication  of  the 
energy efficiency of products at the point of purchase so to make it easier for consumers to 
give  consumers  better  information  regarding  product  sustainability.  It  will  therefore 
present  additional  information  to  the  consumers  on  aspects  that  are  not  covered  by  this 
initiative, as for instance a labelling scheme on their energy efficiency. 

17 https://ec.europa.eu/info/publications/2020-commission-work-programme-key-documents_en  
18 https://ec.europa.eu/info/publications/2020-commission-work-programme-key-documents_en 
https://ec.europa.eu/info/publications/2020-commission-work-programme-key-documents_en  
19 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12798-Energy-labelling-of-
mobile-phones-and-tablets-informing-consumers-about-environmental-impact_en 

3 

 
                                                           
1.2.  Legal context 

Mobile phones and other similar devices as well as chargers are subject to the EU product 
safety legislation which regulate conditions under which they can be lawfully placed on the 
EU market. 

The Radio Equipment Directive 2014/53/EU20 (RED) establishes a regulatory framework 
for  placing  radio  equipment  on  the  Single  Market.  It  concerns  mandatory  market  access 
conditions  of  products  (e.g.  safety,  electromagnetic  compatibility,  efficient  use  of  radio 
spectrum,  access  to  emergency  services,  as  well  as  other  essential  requirements  which 
apply  if  related  delegated  are  adopted)  and  Member  States  (MS)  are  required  to  take 
corrective  measures  on  non-compliant  equipment.  The  RED,  subject  to  the  exclusions 
specified in its Article 1 (2) and (3), covers electrical/electronic equipment that can use the 
radio spectrum for communication and/or radio determination purposes. All mobile phones 
and  radio  devices  such  as  for  example  tablets  or  e-readers  fall  under  the  scope  of  the 
Directive.  It  is  to  be  noted  that  in  the  current  developing  market  trends,  more  and  more 
electrical equipment are capable of wireless communications, therefore fall under the scope 
of the Directive and the pool of devices which can be potentially in scope of this initiative. 
Recital 12 of the Directive further states that interoperability between radio equipment and 
accessories  such  as  chargers  “simplifies  the  use  of  radio  equipment  and  reduces 
unnecessary  waste  and  costs”,  that  a  “renewed  effort  to  develop  a  common  charger  for 
particular categories or classes of radio equipment is necessary”, and that “mobile phones 
that are made available on the market should be compatible with a common charger”. In 
2014,  when  the  Directive  was  adopted,  the  Commission  was  provided  with  an 
empowerment to adopt delegated acts to ensure interoperability of electronic devices with 
common chargers, Article 3(3)(a), and to ensure a common interface, Article 3(3)(c). That 
empowerment does not explicitly state that the Commission can impose one interface for 
ensuring the supply and use of a common charger. 

The  Low  Voltage  Directive21  2014/35/EU  covers  health  and  safety  risks  on  electrical 
equipment  operating  with  an  input  or  output  voltage  of  between  50  and  1000  V  for 
alternating current and 75 and 1500 V for direct current, other than the equipment listed in 
Annex II to that Directive. It allows market access of a wide range of electrical equipment 
for  both  consumer  and  professional  usage.  Electric  power  supply  (EPS)  fall  under  this 
piece  of  legislation  as  regards  safety.  Chargers  with  radio  functions,  however,  fall  under 
the  RED.  The  General  Product  Safety  Directive22 applies  to  products  not  covered  by  the 

20  Directive  2014/53/EU  of  the  European  Parliament  and  of  the  Council  of  16  April  2014  on  the 
harmonisation  of  the  laws  of  the  Member  States  relating  to  the  making  available  on  the  market  of  radio 
equipment and repealing Directive 1999/5/EC, OJ L 153, 22.5.2014, p. 62–106 
21  Directive  2014/35/EU  of  the  European  Parliament  and  of  the  Council  of  26  February  2014  on  the 
harmonisation of the laws of the Member States relating to the making available on the market of electrical 
equipment designed for use within certain voltage limits, OJ L 96, 29.3.2014, p. 357–374 
22  Directive  2001/95/EC  of  the  European  Parliament  and  of  the  Council  of  3  December  2001  on  general 
product safety OJ L 11, 15.1.2002, p. 4–17 

4 

 
                                                           
Union  sectorial  legislation  on  safety  (e.g.  the  Low  Voltage  Directive  and  the  Radio 
Equipment  Directive),  if  they  are  intended  for  consumers  or  likely  under  reasonably 
foreseeable conditions, to be used by consumers – will be regulated by the General Product 
Safety  Directive  2001/95/EC.  If  a  product  is  covered  by  Union  legislation  on  safety,  the 
General Product Safety Directive applies any safety aspects and risks for consumers which 
are not covered by the Union sectorial legislation on safety. It obliges economic operators 
to make sure any dangerous products present on the market can be traced so they can be 
removed to avoid any risks to consumers. When cables are detachable from the EPS, they 
do  not  meet  the  provisions  of  Article  1  of  the  LVD  and  so  they  fall  under  the  General 
Product Safety Directive. The relationship can be visualised as below. 

Table 1 – Parts relationships with EU legislation 

Mobile phone 

Cable 

Electric power supply 
(EPS) 

Applicable safety 
legislation 

Radio Equipment 
Directive 

General Product 
Safety Directive 

Low Voltage 
Directive 

As  regards  counterfeiting,  the  customs  authorities  of  the  EU  Member  States  have  been 
enforcing  Intellectual  Property  Rights  (IPR)  on  the  basis  of  the  Regulation  concerning 
customs enforcement of intellectual property rights23. This regulation provides procedural 
rules  for  customs  authorities  to  enforce  intellectual  property  rights  with  regard  to  goods 
liable to customs supervision or customs control. It (i) specifies the range of IP Rights and 
infringements  that  are  covered,  (ii)  contains  provisions  for  right  holders  on  how  to  ask 
protection  to  customs,  (iii)  determines  procedures  for  customs  to  follow  in  case  of 
identification  of  goods  suspected  of  infringing  an  IPR,  (iv)  provides  provisions  for 
cooperation and exchange of information between customs and right holders, (v) includes 
measures to ensure that the interests of legitimate traders are protected. 

This  initiative  is  linked  to  the  Circular  Economy  Action  Plan24  (CEAP)  that  the 
Commission  adopted  in  March  2020.  The  plan  presents  a  set  of  interrelated  initiatives 
among which the Circular Electronics Initiative (CEI) that refers to regulatory measures on 
chargers  for  mobile  phones  and  similar  devices  and  calls  for  adoption  of  additional 
regulatory  measures  so  that  mobile  phones,  tablets  and  laptops  are  designed  for  energy 

23 Regulation (EU) No 608/2013 of the European Parliament and of the Council of 12 June 2013 concerning 
customs enforcement of intellectual property rights and repealing Council Regulation (EC) No 1383/2003 OJ 
L 181, 29.6.2013, p. 15–34 
24 https://ec.europa.eu/environment/circular-economy/  

5 

 
 
 
 
 
 
 
                                                           
efficiency, durability, reparability, upgradability, maintenance, reuse and recycling. In this 
regard, the Commission is working on three concurrent initiatives.  

The  first  one  is  the  initiative  on  designing  mobile  phones  and  tablets  to  be  sustainable  – 
ecodesign25 which is foreseen for adoption on Q2 2022. The second one is the initiative on 
review ecodesign requirements for computers26 which is foreseen for adoption on Q4 2022. 
The third one is the initiative on energy labelling of mobile phones and tablets – informing 
consumers about environmental impact27 which is foreseen for adoption on Q2 2022.  

Table 2 – Eco-design and Energy labelling Initiatives 

Eco-design for mobile phones and tablets (new 
regulation) 

Product scope 

Smartphones and tablets 

Eco-design for computers (Regulation review) 

Computers  

Energy labelling for mobile phones and tablets (new 
regulation) 

Smartphones and tablets  

Timing 
Q2 
2022 
Q4 
2022 
Q2 
2022 

Another piece of legislation related to this Initiative is the Ecodesign and Energy Labelling 
Working  Plan  2020-202428  (EELWP)  as  part  of  the  implementation  of  the  Ecodesign 
Directive29 and Energy Labelling Regulation30. The Inception Impact Assessment has been 
published31.  The  EELWP  contains  a  specific  item  being  investigated,  the  “universal 
External  Power  Supply  (EPS)”,  on  which  work  has  already  started32.  It  therefore 
complements this Initiative which proposes actions only on the side of mobile phones and 
similar portable devices and which should be therefore considered when regulating on the 
EPS  side.  The  supporting  study  on  “universal  EPS”  follow  the  scope  defined  in  the 
Regulation  on  ecodesign  requirements  for  external  power  supplies33  i.e.,  electric  and 

25 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12797-Designing-mobile-phones-
and-tablets-to-be-sustainable-ecodesign  
26 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1581-Review-of-ecodesign-
requirements-for-computers-and-computer-servers  
27 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12798-Environmental-impact-of-
mobile-phones-and-tablets-Energy-Labelling  
28 https://www.ecodesignworkingplan20-24.eu/  
29 Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a 
framework for the setting of ecodesign requirements  for energy-related products,  OJ  L 285, 31.10.2009, p. 
10–35 
30  Regulation  (EU)  2017/1369  of  the  European  Parliament  and  of  the  Council  of  4  July  2017  setting  a 
framework for energy labelling and repealing Directive 2010/30/EU, OJ L 198, 28.7.2017, p. 1–23 
31 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12852-Ecodesign-and-energy-
labelling-working-plan-2020-2024  
32https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1955-Energy-efficiency-ecodesign-
requirements-for-external-power-supplies  
33  Commission  Regulation  (EU)  2019/1782  of  1  October  2019  laying  down  ecodesign  requirements  for 
external power supplies pursuant to Directive  2009/125/EC of the European Parliament and of the Council 
and repealing Commission Regulation (EC) No 278/2009 

6 

 
 
 
                                                           
electronic devices with power requirements up to 100 Watts having potential to be charged 
by one common power adapter with the industry specifications by USB-IF34. Examples of 
such  products  are:  ear  pods,  rechargeable  battery  chargers,  shavers,  razors,  alarm  clocks, 
radio and loudspeakers, phones and tablets, LED stripes and luminaries, vacuum cleaners, 
cordless tools, computers (including desktop), monitors, televisions, and many more.  

The “universal EPS” study investigated the environmental benefits of having one common 
EPS and touch up on possible environmental impacts of such requirement. The findings of 
this  study  will  lead  to  a  revision  of  the  EPS  regulation  foreseen  in  2022.  In  fact,  the 
supporting  study  recommended  “to  include  the  product  group  in  the  Working  Plan  for 
further  assessments  including  refining  the  scope  and  developing  implementing  measures. 
There is a reasonable amount of energy savings related to resource efficiency and it is an 
area of interests for EU citizens who experience EPSs kept in stock but without any use”.35 
The  revision  of  the  EPS  regulation  will  among  others  concentrate  on  promoting 
interoperability  in  terms  of  charging  performance  of  charger  with  standardized  charging 
protocol  (USB  PD)  and  ensure  citizens  have  enough  information  as  to  make  informed 
choices  when  they  decide  to  buy  a  new  charger  which  will  give  an  intelligible  and 
immediate tool to understand the performance of the charger used with a device when they 
use  a  universal  external  power  supply.  One  of  the  preconditions  to  achieve  a  “universal 
charger”  is  a  minimum  ground  on  the  performance  that  both  the  end-device  and  EPS 
guarantee.  The  combination  of  this  initiative  and  the  revision  of  the  EPS  regulation  will 
ensure,  in  a  complementary  manner,  that  this  minimum  performance  is  met  and  that 
consistent information is given to the consumers. In particular: 

In  order  to  charge  in  an  optimum  manner,  the  device  and  the  charger  should  be 
interoperable, e.g. preventing unjustified limitations of the maximum delivered power and 
supporting at least the same connector. The end-device maximum accepted power will be 
displayed  and  the  charger’s  capacity/power  will  be  included  in  the  labelling  under  the 
EPSs initiative; 

Fast  charging  needs  to  be  supported  at  both  the  end  device  and  the  EPS  side.  For  this 
reason, interoperability needs be ensured and a parallel strand of work on EPS will make it 
possible to inform users appropriately. 

Therefore, this initiative, is fully complementary to the planned one on “universal EPS” by 
ensuring interoperability on both sides of the cable. The interoperability on the device end 
will be achieved by this initiative. In a complementary manner, the interoperability on the 
EPS will be achieved by the initiative on the universal power supply. Although adoption of 
these  initiative  has  a  different  timetable  in  the  Commission  planning,  the  different 
procedures for adoption will make them applicable approximately at the same time, so to 
maximise the coherence and the effectiveness of the EU action. 

34 USB Implementers Forum, Inc. www.usb.org  
35 Point 6.2.7 of task 4 or the preparatory study. 

7 

 
                                                           
Another  objective  of  the  CEI  in  close  relation  with  the  analysis  of  the  environmental 
impacts  of  this  initiative,  is  the  call  for  improving  the  collection  and  treatment  of  waste 
electrical  and  electronic  equipment36.  The  Commission  is  exploring  options  for  an  EU-
wide take back scheme to return or sell back old mobile phones, tablets and chargers. The 
results of the study will be published in Q2 2021 (within the CEI communication), which 
will  provide  the  hooks  for  any  potential  further  action  under  the  Directive  on  waste  of 
electrical and electronic equipment (WEEE)37. 

Finally,  there  is  an  ongoing  study  for  a  possible  introduction  of  a  product  passport  to 
increase the information on product characteristics along the value chain and to consumers 
and  facilitate  product  repair,  upgrading,  component  recovery  and  reuse,  and  ultimately 
recycling  as  part  of  the  Sustainable  Product  Initiative38  (SPI)  Impact  Assessment.  As  of 
now, the SPI is planned in the CWP for adoption in Q4 2021. 

2.  PROBLEM DEFINITION 

2.1.  What are the problems? 

A study carried out after the adoption of the RED in 201439 found that the MoU signed in 
2009  was  effective  at  harmonising  charging  solutions  and  improving  consumer 
convenience. However, full harmonisation of the charging solutions had not been achieved. 
In  addition,  the  study  also  recognised  that  unbundling  had  not  been  achieved  to  any 
significant  extent, with  only  a handful of companies in  Europe offering the possibility to 
consumers to buy a phone without the charger40, hence limiting the expected benefits for 
the environment.  In more general terms, two main problems drive this initiative: the first 
one is the consumer convenience, as repeatedly called by the European Parliament and the 
Consumers’  associations  (see  section  1.1.1),  the  second  is  the  environmental  benefits,  as 
outlined  in  two  further  commissioned  studies  of  2019  and  202141.  As  regards  an 
explanation of the terminology used in this Impact Assessment and a more detailed report 
on the state-of-play of the wired and wireless charging solutions for the equipment in scope 
of  this  initiative,  we  refer  to  Figure  1  and  Annex  5.  That  Annex  and  the  glossary  also 
contains a technical description of certain terms which are used in the next Sections. The 
problems can be clustered as follows:   

36 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical 
and electronic equipment (WEEE), OJ L 
197, 24.7.2012, p. 38. 
37 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012L0019-20180704  
38 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12567-Sustainable-products-
initiative 
39 https://op.europa.eu/en/publication-detail/-/publication/4b3e4ea8-4f44-4687-96e4-
cd3264407c5b/language-en  
40 Currently: Apple’s Iphone 12 and Samsung’s Galaxy s21. 
41 https://op.europa.eu/en/web/eu-law-and-publications/publication-detail/-/publication/c6fadfea-4641-11ea-
b81b-01aa75ed71a1  

8 

 
 
                                                           
Figure 1 – Description of elements for the charge 

In  a  first  instance,  there  is  a  consumer  inconvenience.  Some  of  the  sold  devices  use 
proprietary  connectors  and/or  charging  protocols  that  are  not  always  interoperable  with 
other chargers, or that cannot charge at the same speed when using a charger from another 
brand. This is aggravated by the fragmentation in terms of connectors used, with devices 
using  USB  Type-C,  USB  micro-B  and  proprietary  ones.  And  it  is  also  aggravated  by 
fragmentation of performance of the charging solutions as charger give different charging 
speed depending on the communication protocol used.  

The  second  part  of  the  problem  is  that  there  are  more  chargers  in  the  market  than  what 
consumers realistically need or want.  Most consumers already have one or more suitable 
chargers, so do not always need a new one with each phone. However, with some recent 
exceptions on new models42, manufacturers continue selling chargers along with phones by 
default.  This  generates  unnecessary  use  of  raw  materials,  Green  House  Gasses  (GHG) 
emissions and e-waste.  

The following two sections explain the problems with more granularity. 

42 Apple, Samsung, Nokia and HMD, as of October 2020 

9 

 
 
 
 
                                                           
2.1.1.  Consumer matters 

A number of issues around the current fragmentation of mobile phone chargers and, more 
broadly, of chargers for different electronic devices were raised by the consumers and their 
associations  participating  to  the  Public  Consultation  and  in  the  consumer  surveys  (see 
Annex  2).  The  sources  of  consumer  inconvenience  identified  via  the  surveys  can  be 
divided  into  four  issues:  (i)  inability  to  charge  certain  devices  (as  fast)  with  certain 
chargers; (ii) too  many  chargers taking up place at  home; (iii) no access  to  a  compatible 
charger; and (iv) confusion about which charger works with what device. In more detail, 
participants  in  the  consumer  survey  were  asked  whether  they  had  experienced  any 
problems when using a mobile phone charger in the 24 months prior to the survey. 84% of 
respondents  reported  having  experienced  at  least  one  of  the  different  types  of  problems. 
The most commonly cited problems  can be clustered as:  redundancy of  chargers, lack of 
interoperability,  lack  of  information,  safety  issues.  These  findings  from  the  surveys  of 
consumers43  generally  point  to  lack  of  interoperability  as  the  main  cause  of  consumers’ 
inconvenience. This lack of interoperability consists of the following elements: absence of 
a common connector, inability to charge certain  devices as fast with certain chargers and 
the lack of information provided to consumer as regard the charging performance of their 
device with certain chargers.  

  Interoperability at the device end  

The initial MoU partially resolved the issue of fragmentation of the interfaces (i.e. type of 
connectors used in a device to connect a charging cable), reducing the original number of 
charging solutions for phones from 30 to only 344. However, both the European Parliament 
and  the  consumer  associations  stress  that  the  incomplete  harmonisation  of  the  device 
interface  is  still  inconvenient  for  consumers  (see  section  1  and  annex  2).  The  estimates 
show  that  there  are  around  20%  of  smartphones,  27%  of  tablets,  11%  of  handheld 
videogame  consoles,  and  100%  of  wired  smartwatches  with  proprietary  connector45  46  47 
and de facto, this ratio is aligned with the percentages of cables ending with a proprietary 
connector  (see  section  2.3).  Moreover,  about  39%  of  mobile  phones,  particularly  the 
cheapest  ones,  still  use  the  micro  USB  type-B  connector.  Having  different  chargers  for 
different electronic devices, in fact, was indicated as a source of confusion, especially for 
older people or people affected by disabilities48. 73% of EU citizens believed that users of 
different electronic devices  need to  have multiple chargers which occupy space and may 
lead  to  confusion  to  be  a  serious  problem,  while  26%  of  respondents  described  this  as  a 
minor problem. Only 1% of did not consider it a problem. 

43 https://data.europa.eu/doi/10.2873/788086  
44 https://ec.europa.eu/docsroom/documents/2417/attachments/1/translations/en/renditions/native 
45 https://www.gartner.com/en/newsroom/press-releases/2021-02-22-4q20-smartphone-market-share-release  
46 https://www.statista.com/statistics/1168529/global-apple-market-share-2020/  
47 https://data.europa.eu/doi/10.2873/788086  
48 See also Annex 2 

10 

 
                                                           
In addition, the charging interfaces that are currently found in mobile phones can be used 
not only for delivering power to the battery, but also to communicate with accessories and 
certain  peripherals.  When  specific  manufacturers  do  not  include  a  common  interface  in 
their  products,  there  is  a  risk  of  locking  the  consumer  into  ecosystems  of  accessories  or 
peripherals,  which  may  discourage  the  migration  to  different  brands  and  may  result  in 
more  e-waste  when  a  consumer  decides  to  do  so.  Additionally,  market  developments  for 
tablets and laptops already head towards the use of USB type C connector, also for those 
manufacturers  who  used  proprietary  connectors.  Considering  that  proprietary  interfaces 
have  higher  retail  prices  than  non-proprietary  (USB  types)49,  the  lack  of  a  common 
interface has an effect on the price paid by those consumers for accessories (and also incite 
consumer to buy counterfeit products). 

The progressive introduction of the wireless charger can possibly be a source of additional 
fragmentation.  As  described  in  Annex  5,  different  pads  already  exist  and  the  lack  of 
interoperability can be the start of a new fragmentation of the market. 

  Interoperability in relation to charging performance  

There is quite a high degree of interoperability of chargers. It is also the case as regard to 
fast  charging,  since  most  manufacturers  implement  the  USB  Power  Delivery  (PD) 
technology50  as  a  charging  protocol  (i.e.  in  simple  terms  the  communication  rules  and 
signals for the device to communicate with a charger). However, some manufacturers (see 
Annex 5 for details) use proprietary charging protocols that are either not interoperable or 
when  connected  to  non-proprietary  chargers  reduce  the  charging  speed51.  The  survey 
conducted for the related study52, found that most of consumers that bought a separate EPS 
did  not  encounter  any  problems,  and  similarly  for  those  who  bought  a  cable  separately 
(71%  and  70%  respectively).  However,  those  that  experienced  problems  indicated  issues 
such  as  reduced  charging  speed  (16%  for  EPS  and  15%  for  the  cable),  or  that  the  new 
charger component cannot charge the mobile phone (8% for the EPS and 6% for the cable). 
It should be clarified that, at least for small products such as smartphones or tablets, cables 
do not have any impact on the charging performance if a cable with suitable connectors on 
both sides is used to charge a phone. The targeted interviews have also highlighted that the 
power  may  be  limited  on  purpose  in  those  cases  where  a  phone  using  a  proprietary 
charging  protocol  is  charged  with  an  EPS  not  implementing  that  specific  fast  charging 
protocol,  in  order  to  ensure  safety.  The  result  can  be  a  reduction  of  the  charging 
performance, e.g. the charging process will not deliver the theoretical peak power because 
either the EPS or the mobile phone limit it. It was also underlined how the absence of clear 

49 https://data.europa.eu/doi/10.2873/788086  
50 IEC 62680-1-2:2018 or, more recently, IEC 62680-1-2:2021 – see Annex 5 for details 
51 Huawei SuperCharge and Oppo VOOC are proprietary charging protocols with 22% and 1%, respective 
market shares 
52 https://data.europa.eu/doi/10.2873/788086  

11 

 
                                                           
labelling  may  make  it  hard  to  identify  the  differences  among  chargers,  or  to  understand 
whether a charger is suitable for a given device. Clearer labelling was suggested. 

  Interoperability with other portable devices 

Mobile  phones’  peak  charging  power  typically  ranges  between  5W  and  18W  if  they 
include  USB  PD  technology  or  other  fast  charging  solutions.  EPSs  delivering  power  are 
becoming more and more available on the market53 as the USB PD protocol can support, in 
the  current  version,  up  to  100W.  Devices  with  similar  charging  power  characteristics  to 
mobile phones include, for instance, e-readers, tablets, wearables and cameras. They do not 
include laptops as laptops may require more power, which poses technical challenges when 
it comes to sharing the EPS with a mobile phone, i.e. these chargers can charge a laptop, 
but  only  very  slowly  (e.g.  overnight)  and  may  not  provide  sufficient  power  to  fully 
compensate  the  energy  depleting  the  battery..  However  an  EPS  incorporating  USB  PD 
protocol  and  capable  of  delivering  higher  power  than  needed  by  the  device,  can  safely 
power any device supporting the suitable fast-charging protocol, which is USB-PD. 

Sales  of  those  other  small  portable  devices,  having  similar  charging  characteristics  to 
phones,  (i.e.  tablets,  e-readers,  hearables,  digital  cameras,  sport  cameras,  handheld 
videogame consoles) can be estimated at approximately 260 million devices in the EU27 
annually54. Adoption  of a standardised interface  for these devices  appears to  be possible. 
However, certain devices which have to meet specific conditions (e.g. to be water proof or 
to fit a limited space in the product) would have to be excluded. As a result, the scope of 
this  initiative  and  the  issue  of  interoperability  may  concern  approximately  390  million 
devices55 sold annually in the EU27 (Annex 5 provides further details on the typology of 
other  devices  and  their  charging  needs).  Nearly  all  the  consumer  associations  consulted 
stressed that the presence of different types of connectors and chargers and fast charging 
incompatibilities is inconvenient for portable device users56.  

  Safety issues and counterfeit chargers 

Based on the consumer survey, it is assumed that 5-10% of all EPSs bought separately in 
the  EU,  and  approximately  10-15%  of  cables,  are  counterfeit.  As  regards  product  safety 
issues, 1% of survey respondents who had bought a non-bundled EPS or cable in the last 
24  months  reported  it  had  caused  safety  issues  (e.g.  electrical  shock,  fire…),  while  3% 
reported it had damaged their mobile phone. 5% of those who had bought an EPS, and 7% 
of those who had bought a cable, reported that it broke / become unusable shortly after it 
was bought. Existence of such risks has been documented by an analysis of the number of 

53 IEC 62680-1-2:2018 or, more recently, IEC 62680-1-2:2021 – see Annex 5 for details 
54 broken down as follows, tablets  20.7m, e-readers 16.2m, wearables  116m, digital cameras 54.2m, sport 
cameras 3.2m, videogame devices 52.1m, see https://op.europa.eu/en/publication-detail/-
/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1 
55 160 million mobile phones and 230 million other portable devices. 
56 idem  

12 

 
                                                           
risk alerts for mobile phone chargers in the RAPEX57 and ICSMS58 systems. Overall, the 
RAPEX  and  ICSMS  data,  supported  by  feedback  from  authorities,  suggest  that  there  are 
problems with chargers and that these are increasing, although data in 2017-2018 does not 
confirm  a clear trend59. There  appears to  be a substantial  market  for  counterfeit EPS and 
cables,  which  bring  significant  losses  to  intellectual  property  rights  (IPR)  holders,  and 
could also constitute serious safety threats to users, and negatively impact the environment. 
According  to  data  on  the  EU  customs  enforcement  of  IPR,  the  category  ‘parts  and 
technical accessories for mobile phones’ (including chargers) occupied the 8th place in the 
ranking of top categories of detained articles, with almost 1.1 million of articles in 202060, 
which is comparable to the previous years, for a total value of approximately 45 M €.  

  Bundling vs unbundling  

The  number  of  chargers  shipped/sold  is  higher  than  consumers  need.  Most  of  devices, 
including mobile phones, are sold bundled with a charger in the box. As of October 2020, 
two  major  manufacturers  of  mobile  phones,  accounting  for  roughly  50%  of  the  market 
share61, announced the removal of the EPS (and other accessories) from the retail box of 
certain (not all) new models, explaining that the aim is “further reducing carbon emissions 
and avoiding the mining and use of precious materials, which enables smaller and lighter 
packaging, and allows for 70 percent more boxes to be shipped on a pallet”62 or “minimise 
the  impact  that  products  have  on  the  environment”  in  order  to  support  users  in  making 
“sustainable choices in their daily lives to promote better recycling habits”63. Other three 
manufacturers64 have followed thereafter, on new models. However, certain manufacturers 
are  likely  not  to  introduce  unbundling  voluntary,  as  per  the  interviews.  Therefore,  the 
number  of  chargers  on  the  market  will  continue  to  exceed  the  number  of  chargers  that 
consumers would buy in a well-functioning market, thus leaving untapped the full potential 
to reduce environmental impacts (see section 2.1.2 below). 

A  mapping  exercise65  has  shown  that  unbundling  of  the  EPS  from  the  device  is  already 
common  in  certain  categories  of  products,  such  as  low-power  using  hearables,  e-readers, 
and  portable  speakers,  whilst  it  is  rare  for  devices  such  as  digital  cameras,  portable 
videogame consoles and tablets requiring certain higher power levels. As regards the cable 
assembly,  a  suitable  one  is  almost  always  provided  in  the  box.  In  some  cases, 

57 RAPEX is the EU rapid alert system for dangerous non-food products  
58 The Information and Communication System on Market Surveillance  
59 https://op.europa.eu/en/publication-detail/-/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1  
60 https://ec.europa.eu/taxation_customs/sites/taxation/files/ipr_report_2020.5464_en_04.pdf  
61 Apple and Samsung https://www.statista.com/statistics/1169503/regional-smartphone-market-share-in-
europe/ 
62 https://www.apple.com/newsroom/2020/10/apple-introduces-iphone-12-pro-and-iphone-12-pro-max-with-
5g/, 
63 https://op.europa.eu/en/publication-detail/-/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1 
64 Nokia, Xiaomy and HMD 
65 https://data.europa.eu/doi/10.2873/788086  

13 

 
                                                           
manufacturers fear to lose market shares if they unbundle. In turn certain consumers, being 
unaware  of  the  interoperability,  may  keep  preferring  bundled  solutions,  originating  a 
vicious cycle. 

In a consumer panel survey conducted for the related study66 and focusing on unbundling 
of chargers, 82% of consumers indicated that they consider finding an EPS in the box with 
a new mobile phone very important or important, whilst an even larger share of consumers, 
89%, considered that it was very important  or important  that a cable was supplied in  the 
package  with  a  new  phone.  The  consumer  preferences  are  clearly  not  homogenous  in 
respect  to  unbundling.  They  are  however  partially  consequence  of  still  existing  issues  of 
interoperability, the lack of correct information on suitable chargers among the laypersons, 
and  the  relatively  novelty  of  standards  supporting  possibly  universal  chargers.  When 
provided  with 
interoperability,  charging 
performance  and  product  safety  risks  had  been  provided,  these  proportions  decreased  by 
around 10% points resulting in around three quarters of respondents still maintained it was 
very  important  or  important  for  them  that  EPS  and  cable  are  provided  with  the  phone. 
Additionally, the stakeholder survey showed that the majority of stakeholders request that 
all mobile phones are interoperable with any EPS (75% see figure 2.10 in Annex 2).  

information  on  environmental 

impacts, 

A specific matter concerning unbundling is the retail price of devices and chargers. In the 
interviews, manufacturers announced that they would offer EPS out of the box at a reduced 
price  if  unbundling  becomes  mandatory.  This  appears  to  be  confirmed  by  the 
manufacturers who have started to unbundle, who commented that they have reduced the 
price of their stand-alone EPS67.  

2.1.2.  Environmental aspects 

It  is  estimated  that  in  2019,  266  million  mobile  phones  were  sold68  in  Europe69.  As  a 
conservative mere ratio of the population, in the EU27 approximately 160 million mobile 
phones were sold in that year. Adding more than 260 million portable devices described in 
the previous section, there were therefore approximately 420 million70 portable electronic 
devices sold annually in the EU. When each of them are dispatched with a charger, the old 
ones  either  become  unused  or  are  disposed  of.  In  the  EU27  it  can  be  estimated  that 

66 https://data.europa.eu/doi/10.2873/788086  
67 https://data.europa.eu/doi/10.2873/788086  
68 https://www.statista.com/outlook/cmo/consumer-electronics/telephony/mobile-
phones/europe?currency=EUR#volume  
69  Albania,  Armenia,  Austria,  Azerbaijan,  Belarus,  Belgium,  Bosnia  and  Herzegovina,  Bulgaria,  Croatia, 
Cyprus, Czechia, Denmark, Estonia, Finland, France, Georgia, Germany, Greece, Hungary, Iceland, Ireland, 
Italy,  Latvia,  Lithuania,  Luxembourg,  Malta,  Moldova,  Montenegro,  Netherlands,  North  Macedonia, 
Norway,  Poland,  Portugal,  Romania,  Russia,  Serbia,  Slovakia,  Slovenia,  Spain,  Sweden,  Switzerland, 
Turkey, Ukraine, United Kingdom 
70  see  footnote  54,  assuming  no  chargers  sold  at  all  for  tablets,  cameras,  videogame  devices  as  in  the 
unbundling considerations in the previous section 

14 

 
                                                           
approximately 20 Kg of e-waste per capita were produced in 201971, with a growing trend 
at global level72. Of these, it is estimated that chargers represent 0.3% of the total e-waste 
(11.000 tonnes of e-waste annually)73. As regards the standalone markets, EPS and cables 
for tablets, earbuds, headphones and cameras are estimated74 to account for less than 20% 
of the stock of mobile phone EPS and cables (including those purchased on their own). 

The consumer panel survey suggests that the average consumer owns around three mobile 
phone chargers, of which they use two on a regular basis. A little under half of consumers 
only use a single charger, while the remainder use two or more. Survey respondents also 
reported using an average of two chargers which implies that on average, one changer is 
left unused. There was significant variance in this data, with a few respondents reporting to 
own  as  many  as  25  chargers.  Not  having  the  choice  not  to  buy  the  charger  implies  that 
consumers have more chargers than they need. The results of the consumer survey show 
that  chargers  taking  up  space  at  home  or  at  work  was  indicated  as  an  issue  by  44%  of 
respondents75.  Accumulating  chargers  at  home  was  the  single  most  common  way  of 
dealing with old chargers (49% of cases).  

Certain  manufacturers76  77  have  already  highlighted  the  positive  impact  on  reducing 
emissions  that  unbundling  has  due  to  the  use  of  fewer  materials  for  the  packaging  and 
higher efficiency in the transport of the products. However, other stakeholders have argued 
that  unbundling  will  lead  to  a  higher  amount  of  packaging  material  and  associated 
emissions (as users will potentially buy separately an EPS and cable). Furthermore, a retail 
association during  an interview indicated that  while the packaging of phones is  normally 
cardboard, when EPS are sold separately, they are packaged in plastic.  

2.2.  What are the problem drivers? 

The drivers are different and can be clustered as showed below. At the end of the section, a 
problem tree is produced. 

  Lack of commitment to meet the policy objectives of the Union 

The MoU 2009 resulted in convergence towards a common external power supply (EPS) 
and  USB  micro-B  connectors  at  the  device  end  of  mobile  phones.  The  most  notable 
exception  was  one  single  manufacturer,  continuing  to  use  proprietary  connectors  (from 
2012). Since the expiry of the MoU in 2014, several technological innovations in relation 

71 http://ewastemonitor.info/wp-content/uploads/2020/12/GEM_2020_def_dec_2020-1.pdf , page 76 
72 https://www.statista.com/statistics/499891/projection-ewaste-generation-worldwide/  
73 https://op.europa.eu/en/publication-detail/-/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1 
74 https://data.europa.eu/doi/10.2873/788086  
75  The  problem  occurred  once  or  twice  for  17%  of  consumers,  on  a  few  occasions  for  20%,  on  numerous 
occasions for 12%, and for 5% almost on a daily basis. 
76 Apple (2020) Product Environmental Report. iPhone 12 Pro.  
77 Nokia (2019) People and Planet Report 2019.  

15 

 
                                                           
to  charging  technologies,  EPS,  and  connectors  have  occurred78.  The  new  MoU  on  wired 
chargers for smartphones proposed by the industry in March 2018 was found not to align 
with  the EU’s harmonisation  objectives79. A comparison of the MoU 2009 and the MoU 
2018  shows  that  little  has  been  done  to  promote  the  use  of  a  “universal  charger”,  so  to 
maximise  consumer  convenience  and  environmental  benefits.  On  the  contrary,  the  MoU 
2018 does not provide sufficient reassurance that work is ongoing to resolve the observed 
fragmentation80.  As  a  result,  not  only  the  target  of  having  one  single  connector  has  not 
been achieved, but also progressive fragmentation has been observed in time, by means of 
proprietary features and solutions concerning the technical protocols and performance. The 
general  and  political  “perception”  is  therefore  that  this  convergence  to  a  “universal 
charger” and its wide adoption has been a missed opportunity.  

  Proprietary charging solutions for commercial benefits  

In  some  cases,  interoperability  of  chargers  is  prevented  by  proprietary  protocols  in  the 
EPS,  which  are  not  compatible  with  the  most  common  standard.  Those  protocols  do  not 
allow a correct communication between the source (the EPS) and the device being charged. 
In other cases, interoperability is prevented by specific proprietary connectors on the end-
device.  There  are  different  economic  aspects  linked  to  these  choices.  For  instance,  the 
selling prices of specific accessories of brands using proprietary connectors is higher than 
the average81.  

Some  industry  representatives  interviewed  claim  that  their  proprietary  fast  charging 
solutions  are  more  energy-efficient  than  USB  PD82.  Interviewees  also  claim  that 
proprietary  solutions  are  safe  (apply  several  levels  of  control  to  ensure  the  temperature 
stays low), charge phones quickly, and the production cost is lower than if they used USB 
PD.  These  manufacturers  generally  include  in  the  box  EPS  and  cables  that  provide  high 
power to allow the fast charge advertised83.  

  Some consumers do not know most chargers are interoperable 

Chargers  and  mobile  phones  can  support  different  power  levels  and  hence  allow  for  a 
degree  of  interoperability,  if  programmed  according  to  existing  standards,  without 
proprietary changes84. In the consumer survey85, less than half of respondents (45%) were 

the  USB  Type  C  has  been  developed  and  its  use  has  progressed,  see  Annex  5  or 

78  e.g. 
https://op.europa.eu/en/publication-detail/-/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1, pages 6-8 
79 , page 7 
80 See also section 5.1 
81 This assessment is based on information provided by interviewees of the supporting studies 
82 It has been reported that Huawei SuperCharge achieves up to 96% of energy efficiency during the charge, 
whereas USB PD reaches up to 80% of energy efficiency. 
83 For instance, the Huawei Mate 40 Pro includes the Huawei Supercharge EPS (66W). With this charger, it 
can be fully charged in 49 minutes 
84 https://op.europa.eu/en/publication-detail/-/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1  
85 https://data.europa.eu/doi/10.2873/788086  

16 

 
                                                           
fully aware that the vast majority of chargers from all major mobile phone manufacturers 
are interoperable, i.e. can be used to  charge  all modern phones irrespective of the brand. 
The  current  level  of  interoperability  however  don’t  guarantee  the  same  fast  charging 
performance  as  there  are  proprietary  charging  communication  protocol  that  do  not  allow 
interoperability. The rest of respondents were either partly aware (36%) or did not know it 
(19%).  Similarly,  in  the  consumer  survey  conducted  for  another  study86,  confusion  over 
which charger to use for different mobile phones was a problem that had been experienced 
by  30%  of  respondents.  For  1%  it  happened  almost  every  day,  for  5%  on  numerous 
occasions, for 12% a few times, and for 13% once or twice. When needing to charge their 
phone, 19% of respondents  reported having experienced problems  once or twice because 
all  other  chargers  were  incompatible,  15%  had  this  problem  on  a  few  occasions,  3%  on 
numerous occasions and less than 1% almost daily. 63% did not face problems relative to 
interoperability  with  other  chargers  than  the  one  from  the  same  brand  as  the  phones. 
Actually consumers, even those willing to reuse their chargers in the assumption that the 
interface is the same, struggle to understand the performance of already-owned chargers in 
charging new mobile phones87.  

The  consumers’  perception  is  therefore  that  no  sufficient  information  is  provided  on  the 
charging capabilities of the equipment. In turn, this makes it very difficult to ascertain the 
extent to which an old charger can meet the charging needs of new devices. The presence 
in the retail box of chargers is therefore perceived as the sole “best-match” to charge the 
device,  making  old  chargers  redundant  and  therefore  disposed  or  dismissed.  Clearer 
labelling  was  suggested  by  consumer  associations  as  a  measure  to  distinguish  chargers 
with  different  charging  features  (e.g.  by  defining  a  limited  number  of  types  of  chargers 
based on their power output and/or specifications, and labelling them accordingly).  

  Some consumers find it convenient to get a charger with each phone 

In  the  consumer  survey  conducted  for  this  study,  82%  of  consumers  indicated  that  they 
consider finding an EPS in the box with a new mobile phone very important or important, 
whilst  an  even  larger  share  of  consumers,  89%,  considered  that  it  was  very  important  or 
important  that a cable was supplied along with  a new phone. Although these proportions 
decreased  by  around  10  percentage  points  after  information  on  environmental  impacts, 
interoperability, charging performance and product safety risks had been provided, around 
three quarters of respondents still maintained it was very important or important for them 
that  EPS  and  cable  are  provided  with  the  phone.  Among  the  consumers  who  found  it 
important to have either an EPS and/or cable in the box, almost half (46%) indicated that it 
is  because  of  habit,  i.e.  they  are  used  to  finding  a  complete  product  in  the  box.  Other 
relevant factors are: safety (50%), performance (48%), and convenience (38%). However, 
the survey also shows that a majority of respondents (61%) were supportive of the idea that 

86 https://op.europa.eu/en/publication-detail/-/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1 
87 https://data.europa.eu/doi/10.2873/788086  

17 

 
                                                           
all  mobile  phone  manufacturers  /  distributors  should  give  customers  the  option  of 
purchasing (or not) a new EPS and/or cable with new phones.  

  Lack of awareness of the environmental impact 

As explained above, until last year, nearly all mobile phones sold in the EU market were 
bundled with an EPS and cable88 and the scenario changed as of October 2020. As per the 
interviews, other manufacturers are  considering the unbundling at the moment, but  those 
with  proprietary  charging  technologies  appear  less  keen,  as  they  consider  their  high 
charging performance an added value. As regards the cable, this is almost always provided 
in the box.  

Consumers  appear  to  be  less  aware  of  the  environmental  impacts  of  chargers.  In  the 
consumer  survey,  less  than  a  third  of  respondents  (29%)  knew  that  chargers’  production 
requires  raw  materials  and  generates  CO2  emissions,  and  when  chargers  are  no  longer 
used,  they  generate  electronic  waste.  38%  of  respondents  partly  knew  this,  and  33%  did 
not  know  it.  Knowing  this  information  changed  slightly  the  extent  to  which  they  think 
having  a  charger  in  the  box  is  important.  The  number  of  respondents  who  thought  it  is 
important  to  have  an  EPS  decreased  from  82%  to  71%,  and  those  who  thought  it  is 
important  to  have  a  cable  decreased  from  89%  to  78%  of  respondents.  A  minority  of 
consumers (6%), however, indicated that it is not important for them to have an EPS in the 
box, and that this is because of sustainability reasons.  

  Concerns on consumers’ reactions 

In interviews89, manufacturers have expressed their concern about consumers’ reactions if 
they  stop  selling  chargers  with  their  devices.  Two  manufacturers  informed  that  they  had 
previously tried unbundling schemes in the past. One camera manufacturer noted that they 
started  selling  their  cameras  without  the  EPS  and  received  very  negative  feedback  from 
consumers.  A  phone  manufacturer  also  noted  that  they  piloted  an  unbundling  scheme  in 
Russia  (in  this  case,  the  phones  were  sold  without  EPS  or  cable),  but  most  consumers 
chose  to  buy  the  charger  when  acquiring  a  new  phone.  The  lack  of  effectiveness  in  the 
scheme also meant that the environmental benefits they were expecting to achieve were not 
realised. 

Figure 2 shows the problem tree. 

88 Only one small manufacturer (Fairphone) offered consumers the option of buying phones without chargers 
89 Annex 2 and more extensively https://op.europa.eu/en/web/eu-law-and-publications/publication-detail/-
/publication/c6fadfea-4641-11ea-b81b-01aa75ed71a1 

18 

 
 
 
                                                           
Figure 2 - Problem tree 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

19 

 
 
 
2.3.  How will the problem evolve? 

In the absence of action to promote a common charging solution, fragmentation is expected 
to continue for the foreseeable future. 

As  regards  the  wired  chargers,  following  the  MoU  of  2018,  the  manufacturers  will  not 
eventually converge to a common solution for connectors and would not phase out existing 
proprietary connectors, as that MoU also allowed to keep the micro USB type-B interface 
and  proprietary  interfaces.  As  regards  the  old  common  connectors  (micro  USB  type-B), 
Figure 5.4 of Annex 5 and a projection of an industry study90, identify that as of 2024 their 
phase-out  will  be  de  facto  completed.  However  the  remaining  proprietary  solution  on 
phone (on other products) will stay. In addition, other manufacturers may wish to introduce 
in  the future new proprietary solutions  (both for  phones  and other devices), if this is  not 
addressed. The fact that, despite the voluntary approach didn’t lead to one single solution, 
the  regulators  didn’t  act,  may  be  even  an  incentive  for  other  manufacturers  to  switch  to 
proprietary  solutions.  Whilst  fragmentation  is  being  observed  also  in  the  uptake  of  the 
wireless  charger,  with  different  protocols,  coils,  interfaces  and  technologies  being 
developed91, there are efforts to converge to a common solution or interoperability. Since 
wireless  charging  enabled  phones  were  first  introduced,  they  have  seen  widespread 
adoption. Between 2016 and 2018, their overall sales increased six fold, rising to  around 
44 million, or around 28% of overall sales in 201892. The largest share of wireless enabled 
phones  sold  throughout  2016-2018  were  from  one  manufacturer  only.  More  recent 
observations of the market were in line with this effort to limit the fragmentation93. In view 
of  the  recently  launched  voluntary  unbundling  initiatives  by  certain  manufacturers,  the 
specific study94 estimates that 25% of phones will be sold without an EPS in the box, and 
that this proportion will increase to 48% by 2023, and more slowly thereafter, to 54% by 
2030.  But,  in  light  of  the  experience  with  the  implementation  of  the  MoU,  voluntary 
initiatives on the matter may not be followed by all active manufacturers in the field.  

Based on the results of the consumer survey, it is estimated that 57% of  consumers who 
purchase an unbundled new phone will choose to purchase one EPS along with the phone. 
However, since these consumers will be able to  choose which kind  of EPS they  acquire, 
demand  for  stand-alone  EPS  bought  at  other  times  (not  along  with  a  new  phone)  will 
decrease, by an estimated 31%. The net effect of these two trends is that, for every phone 
sold without an EPS, it is assumed that an additional 0.39 stand-alone EPS will be bought. 

90 Figures 3-8 and 3-9 of the study in https://www.digitaleurope.org/wp/wp-content/uploads/2019/12/RPA-
Study-Common-Charger-2.0-final.pdf 
91 https://data.europa.eu/doi/10.2873/537546  
92  note  that  these  numbers  refer  to  wireless  enabled  phones,  i.e.  not  to  phones  that  come  with  a  wireless 
charger, but those that can be charged with a wireless charger that needs to be purchased separately 
93 https://data.europa.eu/doi/10.2873/537546 - see also Annex 5 for further details 
94 https://data.europa.eu/doi/10.2873/788086  

20 

 
 
                                                           
In other words, every 100 phones sold without an EPS the total number of bought EPS is 
reduced  by  61  units.  In  2021,  on  the  EPS  side,  there  were  two  main  non-proprietary 
technologies on the market, with respectively 70% (USB Type A) and 30% (USB Type C) 
of  the  share95.  As  a  transition  is  in  place,  this  situation  is  expected  to  reverse  by  2030. 
However,  proprietary  connectors  will  remain  22%  of  the  total.  With  respect  to  EPS,  the 
trend towards more powerful (and faster) EPS is expected to increase in future, with EPS 
providing less than 7.5W reducing to 7% by 2030.  

As regards environmental impacts, high-power quality chargers (both cables and EPS) are 
typically designed to last longer than cheap and low-power chargers96. In the short-medium 
term, the consumption of materials for the production of chargers will increase, as the fast 
chargers  are  heavier  (see  Annex  5).  In  this  timeframe,  an  unnecessary  proliferation  of 
chargers  will  lead  to  consuming  more  resources.  In  the  medium-long  term,  new 
technologies  (such  as  GaN,  Gallium  Nitride)  will  reduce  part  of  the  weight  and  are 
expected  to  increase  the  durability  of  the  chargers  available  in  the  market,  as  indicated 
during the interviews97. In this scenario, the absence of a common interface and minimum 
charging performance and the progress of fragmentation risk to reduce the reuse of these 
devices within their lifetime. 

The material use is estimated98 to increase from 14 584 tonnes in 2017 to 20 969 tonnes in 
2030. From 2017-2024 there is a steady increase in the material used. This is driven by the 
switch to heavier EPS and more robust and durable cables. The increase in material used 
slows in 2023 and 2024 (4% and 2% increase, respectively). This is then followed by an 
overall stabilisation of the material used until 2026, after which there is an annual decline 
of  1-2%  driven  by  increased  adoption  of  lighter  and  smaller  EPS  introducing  new 
components (such as GaN). 

For  context,  the  baseline  annual  average  material  use  (based  on  2024-2030)  of  21  829 
tonnes represents a negligible proportion (0.0005%) of the 4.5 million ktonnes (kt) of total 
material  used  in  the  EU  in  2018.  It  also  equates  to  around  2.6%  of  the  weight  of  small 
household appliances put on the market in the EU in 2018, and so within this category is a 
small  but  non-negligible  contributor.  Without  action,  the  e-waste  is  expected  to  increase 
from 12 574 tonnes in 2018 to 20 177 tonnes in 2030 despite the decline in the number of 
EPS and cables added to the stock of chargers each year as mobile phone sales decline and 
unbundling  increases.  From  2024  onwards,  the  annual  increase  in  e-waste  slows  but 
overall,  the  amount  of  e-waste  generated  increases  gradually  every  year,  as  changes  in 
material use translate to changes in e-waste. The baseline annual e-waste generated in 2023 

95 USB Type-A and USB Type C – see Annex 5 for details 
96 https://data.europa.eu/doi/10.2873/788086 
97 https://data.europa.eu/doi/10.2873/788086 
98 https://data.europa.eu/doi/10.2873/788086 

21 

 
 
                                                           
of  16  616  tonnes  represents  approximately  5.4%  of  the  353  172  tonnes  of  total  small 
household  appliances  collected  from  households  equipment  in  2017.  The  model  assumes 
an increase in the recycling rates of plastics and metals. These recycling rates result in an 
average  increase  of  31%  of  the  e-waste  collected,  and  43%  of  the  e-waste  recovered  for 
recycling between 2024 and 2030 compared to 2024. 

Table 3 - Modelled recycling rates for EPS and cables (2015-2030) 

2015  2020  2025  2030 
Disposal method 
56%  69%  76%  84% 
Disposed to recycling 
44%  31%  24%  16% 
Incorrectly disposed (untreated waste) 
Source: Impact assessment study on Unbundling of mobile phones and 
similar electronic devices (2021) 

The GHG emissions increase from 2017-2023 despite the trend for e-waste. This is driven 
by the switch to faster, more powerful EPS (7.5W and above) and the move to USB Type-
C cables, both of which are heavier than the previously more common low (<7.5W) power 
EPS  and  USB  Micro-B  cables.  The  average  weight  of  an  EPS  +  cable  combination  is 
modelled to increase by 70% from 57g to 97g between 2017 and 2023. The trend in weight 
increase per charger combination stabilises from 2024 onwards and even declines a little as 
lighter  EPS,  e.g.  using  GaN,  become  more  common.  These  effects  lead  to  the  observed 
decline in baseline GHG emissions of 7% between 2023 and 2030. Baseline annual GHG 
emissions in 2023 of 1 142 ktCO2e represent approximately 0.03% of EU GHG emissions 
in  2018. With respect  to other electronic devices, the trend is  as in  the following table99. 
This  confirms  that  the  environmental  problem  is  present  also  in  different  devices  than 
mobile phones.  

Overall,  other  devices  are  smaller  markets  than  for  smartphones.  The  market  of  mobile 
phone  chargers  is  much  larger  than  any  other  market  of  portable  devices  (see  the  Table 
below).  However,  there  is  already  quite  some  inconvenience  coming  from  the 
fragmentation of performances and interfaces for these devices. Together with the high rate 
of unbundling, the consumer inconvenience for these devices can be significant. 

Table 4 – Trends for other devices 

Device 

Tablets 

Sales trend 
(thousand 
units) 
Decreasing 
22 350 (in 
2019) 

Fragmentation 
(interfaces and 
performance) 

Unbundling 
impact 

Considerations 

High 

High 

Closest 
smartphones 
battery 

device 
in 

to 
terms  of 
charging 

and 

99 https://data.europa.eu/doi/10.2873/788086 

22 

 
 
 
                                                           
Cameras 

Decreasing 
5 428 (in 
2019) 

High 

High 

Earbuds and 
headphones 

Increasing 
23 612 (in 
2019) 

High 

Medium 

to  reduce 
likely 

characteristics 
High  potential 
fragmentation  and 
high impact of unbundling 
Very 
fragmented  market 
(type  of  connector)  and 
growing 
All 
products  analysed  include  a 
cable  and  half  of 
them 
include  also  an  EPS.  Some 
earbuds  are  charged  via 
wireless  in  their  box,  and 
the  box  connects  to  an  EPS 
via  a  cable  (common  or 
proprietary).  

market. 

Hand-held 
video game 
consoles 

Constant 
18 598 (in 
2018) 

Low 

High 

Consoles  share  cable  and 
EPS  with  smartphones.  All 
devices  analysed 
the 
mapping are sold with cable 
and EPS. 

in 

Portable 
speakers 

E-readers 

Increasing 
1 639 (in 
2020) 

Constant 
11 838 (in 
2020) 

Medium 

Low 

Low 

Low 

Smartwatches 
and fitness 
trackers 

Constant 
7 658 (in 
2020) 

High 

Low 

in 

has 

Most  of  the  devices  use 
USB 
and 
technologies 
approximately 20% are sold 
with  an  EPS.  The  trend 
towards USB-C and towards 
de-coupling 
been 
interviews 
confirmed 
with manufacturers. 
EPS  typically  included  in 
the  box  and  connectors 
already standardised 
Most  devices  are  charged 
These 
via 
often 
wearables 
designed 
be  water 
to 
resistant  and  support  hard 
conditions,  therefore  USB 
connectors may not offer the 
best solution. 

wireless. 
are 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices 
(2021) 

23 

 
 
2.4. 

Impact of COVID-19 

Different statistics for 2020100 101 102 show that the COVID situation has impacted by 5%-
10%  on  the  sales  of  mobile  phones  and  other  electrical  equipment.  However,  the 
estimates103 foresee a full recovery in 2021 or 2022 the latest, with a growing trend as in 
the  years pre-crisis.  For  the purposes of the environmental benefits,  is  therefore assumed 
that the COVID-19 situation will not impact the overall findings and policy options. 

On  the  contrary,  as  regards  the  consumer  convenience,  the  Economic  and  Budgetary 
Outlook for the European Union 2021104 notes that “despite being protected by government 
measures,  aggregate  labour  income  is  set  to  decrease  in  2020  as  many  companies  defer 
decisions  about  employing  new  staff,  or  reduce  working  hours  or  staff  numbers.  Some 
segments of the workforce are likely to be affected more than others, with the incomes of 
lower-wage  earners  and  younger  cohorts  showing  greater  vulnerability  to  downturns”. 
This  is  confirmed  also  by  Eurostat105,  which  also  registered  a  rise  to  the  unemployment 
rate106. All this makes consumers more vulnerable and therefore the effects of COVID-19 
require to pay specific attention to the consumer convenience (e.g. costs, interoperability or 
reusability) which has been described in section 2.1.1. 

3.  WHY SHOULD THE EU ACT? 

3.1.  Legal basis 

The legal basis for this initiative is the RED, which is based on Article 114 of the TFEU. 
The way in which the RED will be used in support of the current initiative is described in 
section 8.1, with respect to the preferred policy option. As the RED does not cover EPS, 
this initiative focuses on the end-device, not their chargers or chargers’ components. 

3.2. 

Subsidiarity: Necessity of EU action 

EU intervention in this area is a common interest for consumers and the environment. As 
outlined above, the EU needs to make sure that products placed on the EU market support 
the  consumer  convenience  and  are  rationalised  so  to  allow  the  reduction  of  e-waste, 
promoting the objectives of a circular economy.  

100 https://ec.europa.eu/eurostat data code STS_TRTU_A  
101 https://www.gartner.com/en/newsroom/press-releases/2021-02-03-gartner-says-worldwide-smartphone-
sales-to-grow-11-percent-in-2021  
102 https://www.statista.com/outlook/cmo/consumer-electronics/telephony/mobile-
phones/europe?currency=EUR#revenue  
103 as in the previous 2 footnotes 
104 https://www.europarl.europa.eu/RegData/etudes/STUD/2021/679062/EPRS_STU(2021)679062_EN.pdf  
105 https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Impact_of_COVID-
19_on_employment_income_-_advanced_estimates&stable=1  
106 https://ec.europa.eu/eurostat/web/covid-19/society-work  

24 

 
                                                           
lack  of 

interoperability,  unjustified  difference 

The  technology  for  chargers  is  available  and  sufficiently  flexible  for  charging  multiple 
categories  of  equipment.  Harmonisation  of  charging  solutions  has  to  be  developed  in  a 
manner that supports the policy objectives of the Union in terms of circular economy and 
in 
consumers’  convenience.  The 
performance  and  the  related  consumers’  inconvenience  affect  an  effective  and  efficient 
functioning  of  the  internal  market,  where  the  absence  of  harmonisation  may  lead  to 
substantial  differences  between  the  Member  States'  laws,  regulations,  administrative 
provisions or practices. Without EU action, the trend (see section 2.3) is that fragmentation 
of  connectors,  EPS  and  performance  will  persist.  The  size  of  the  internal  market  in 
recharging mobile phones and similar devices and the fragmentation of different chargers 
on the Union market call for stronger action at Union rather than national level to achieve 
the smooth functioning of the internal market.  

It  is  therefore  necessary  to  ensure  that  citizens  do  not  suffer  an  unjustified  level  of 
fragmentation  when  charging  certain  categories  of  radio  equipment  and  that  no  waste  is 
produced  by  unnecessary  sales.  A  basis  for  adapting  harmonisation  in  this  area  with  any 
new technology, relating to wired or wireless charging, shall also be provided.  

3.3. 

Subsidiarity: Added value of EU action 

An  EU  action  will  guarantee  that  the  objectives  of  consumer  convenience  and  WEEE 
reduction  apply  at  the  Union  level.  It  will  also  prevent  manufacturers  to  be  subject  to 
different  possible  national  initiatives  that  aim  to  achieve  the  same  objectives  in  a  non-
harmonised manner and would lead to obstacles to the free movement of goods within the 
EU. It would ensure that sufficient information is provided to consumers. Such measures 
must,  therefore,  have  the  same  content  throughout  the  EU.  In  line  with  the  principle  of 
subsidiarity, it is thus appropriate for the measure in question to be adopted at EU level. 

EU  action  will  also  allow  enforcing  measures  when  products  are  placed  on  the  market 
according to the principles laid down in the Internal Market legislation of the Union. MS 
do not have a legislative tool to recall or to impose corrective measures to the equipment 
that does not facilitate the consumer convenience or creates excessive e-waste. The status 
quo has likewise implicit quantifiable and non-quantifiable impacts which are expected to 
persist, as a minimum, despite the long-standing request to reduce the fragmentation in the 
sector. A response is therefore needed.  

A regulatory action at the EU level will consequently fit a coherent implementation of the 
EU  law,  supporting  the  development  of  the  Internal  and  Digital  Single  Markets  and 
providing legal certainty for both manufacturers and consumers.  

An EU regulatory action will also apply to all manufacturers in a non-discriminatory way, 
thus  establishing  a  level-playing  field  on  the  EU  market  for  the  equipment  in  scope, 
harmonising the requirements that are to be demonstrated in the Union for market access. 

Setting specific requirements for interoperability, i.e. charging performance and interfaces, 
will make it easier to assess the quality of chargers on the market, and hence. In turn, this 

25 

 
will  provide  Market  Surveillance  Authorities  with  precise  benchmarks  to  ascertain  the 
correct functioning of chargers and therefore contribute to a better implementation of the 
internal market.  

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

4.1.  General objectives 

The  general  objectives  is  to  increase  consumer  convenience  and  achieve  environmental 
benefits  through  an  initiative  concerning  a  common  charging  and  unbundling  for  mobile 
phones and other portable devices which have similar charging needs. 

4.2. 

Specific objectives 

The  general  objectives  in  the  previous  section  will  be  achieved  through  the  following 
specific objectives which aim to reduce the impact of the problems described in section 2: 

1.  In a first instance the aim is to promote interoperability reducing the fragmentation 
in terms of end-device connector of mobile phones and other portable devices;  
2.  In  a  second  instance,  the  aim  is  to  promote  interoperability  in  terms  of  charging 

performance of devices, including fast charging; 

3.  In  a  third  instance,  ensure  citizens  have  enough  information  as  to  make  informed 
choices  when  they  decide  to  buy  a  new  device.  Consumers  shall  be  given  clear, 
intelligible  and  immediate  tool  to  understand  the  performance  of  the  electronic 
devices  and  which  charging  accessories  shall  be  used  to  achieve  the  optimal 
performance. This point will be complemented by a parallel initiative on common 
EPS (see section 1.1.2) under a different legal basis107;  

4.  Furthermore, provide consumers with a choice as to whether they want to acquire a 

new charger when they purchase electronic devices; 

5.  Finally,  the  pool  of  devices  in  scope  of  the  initiative  is  to  be  extended  to  the 
maximum  possible,  in  the  respect  of  the  charging  requirements,  technologies  and 
uses. The devices analysed for  a possible inclusion are  radio  devices with similar 
charging characteristics than mobile phones, as in section 5. 

The  use  of  a  common  interface,  supported  by  interoperability  as  to  the  charging 
performance, adequate information to the users and offer of unbundled solutions will allow 
consumers to be in a position to assess on a more solid  ground whether they need a new 
charger.  This  in  turn  will  allow  to  reduce  unnecessary  purchases  and  reduce  the 
environmental impact of chargers, which will even be more effective by extending the pool 
of devices in scope of this initiative. Therefore the attainment of the specific objectives on 
consumer  convenience  are  linked  to  the  environmental  specific  objective  of  reducing  e-

107 Directive 2009/125/EC of 21 October 2009 establishing a framework for the setting of ecodesign 
requirements for energy-related products. 

26 

 
                                                           
waste. Finally, the complementary of the present initiative with the up-next initiative under 
eco-design  towards  a  universal  external  power  supply  will  allow  to  achieve  the  ultimate 
goal of the “common charger”. 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

The  different  policy  options  include  a  status  quo  option,  non-regulatory  and  regulatory 
options. The latter ones have been built on the hypothesis of an ad-hoc amendment of the 
RED and taking into account parallel initiatives on EPS, which are planned for next year 
(see section 1 and Annex 5). The assessment of policy options has taken into consideration 
the  extent  to  which  the  different  policy  options  could  achieve  the  policy  and  regulatory 
objectives set out above and in the Commission’s inception impact assessment108. Different 
consultations of the Expert Group on Radio Equipment took place to verify the extent to 
which  the  policy  options  could  respond  to  the  stakeholders’  and  the  Member  States 
expectations.  The  policy  options  have  been  built  as  a  function  of  the  different  possible 
measures  presented  in  the  following  points,  each  of  them  tackling  different  specific 
objectives. They have been packaged according to the level of ambition of the EU action: 

1.  Harmonisation of the end-device interface: this has been the objective of the MoUs of 
2009  and  2018.  The  aim  of  this  measure  is  to  ensure  a  degree  of  interoperability 
requiring mobile phones and/or other devices to have a common interface. The aim is to 
have  the  most  common  solution  used  on  the  market  (USB  Type  C  –  see  Annex  5) 
harmonised across all devices in scope.  

2.  Interoperability in terms of charging performance: supporting interoperability with USB 
PD communication protocol by the device: this can be left to the market (no action) or 
to a mandatory measure, ensuring that appropriate protocol and performance (see Annex 
5) are implemented in all devices, in a proportionate manner;  

3.  Making unbundled solutions available on the market: this measure aims to minimise the 
sale  of  EPS  together  with  the  devices,  favouring  the  re-use  of  existing  chargers,  and 
minimising the need to buy new chargers. It can be implemented in two ways, i.e. either 
placing  on  the  market  only  unbundled  solutions  or  placing  on  the  market  at  least 
unbundled solutions (a manufacturer could offer both). It can be mandated or left to a 
market approach (no action); 

4.  Informing  consumers  about  charging  performance:  this  measure  aims  to  inform 
consumers  on  the  charging  capabilities  of  the  devices  they  intend  to  buy,  so  that  they 
can  understand  whether  they  can  re-use  their  old  charger  and  to  which  extent.  It  will 

108 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/2020-Common-chargers-for-
mobile-phones-and-similar-devices  

27 

 
 
 
 
                                                           
allow consumers to compare the charging performance of the device with the EPS and 
match them as appropriate. To do so, the following information should be displayed: 

  The  maximum  power  that  the  device  can  take  will  be  indicated  on  the  device. 
The standard allows for downward compatibility, i.e. devices supporting higher 
power can also operate at lower powers.  

  The support of the common fast charging communication protocol. 

The same requirements  will have to  be displayed on the EPS (which for numerous of 
them  it’s  already  the  case),  this  will  be  implemented  through  the  revision  of  the  EPS 
regulation. This is considered to be a flanking measure to the second measure and are 
merged because closely linked to each other (see also section 5.3); 

5.  An  additional  dimension  is  the  scope  of  the  initiative:  the  equipment  in  scope  of  the 
options  can  be  narrow  (mobile  phones  only)  or  broad  (certain  devices  with  charging 
characteristics which are comparable to  a mobile phone). The issue of scope could  be 
considered as a sub-option of all the possible policy options. 

How these measures are combined into policy options is reported in Section 5.2.  

The safety of chargers, the reduction of counterfeit products and the promotion of quality 
and  durable  products  will  not  be  directly  supported  by  this  initiative.  The  planned 
initiatives on Eco-designs and common EPS (see section 1.1.1) will complement to achieve 
quality and durable products. In terms of safety, the pending evaluation of the Low Voltage 
Directive showed that the rules concerning safety of EPS are fit for purpose. There are a 
number  of  recent  and  upcoming  initiatives  related  to  market  surveillance  and  improved 
enforcement of IPR rules that should have a positive impact on the safety of chargers and 
reduction  of  counterfeit  chargers  on  the  market.  In  particular,  the  Regulation  (EU) 
2019/1020  on  market  surveillance  and  compliance  of  products  supports  fairer  internal 
market for goods, through fostering more cooperation among national market surveillance 
authorities.  This  includes  sharing  information  about  illegal  products  and  ongoing 
investigations so that authorities can take effective action against non-compliant products.  

As a consequence, before taking further action on the safety of chargers and the reduction 
of  counterfeit,  it  is  appropriate  to  assess  the  effectiveness  of  the  implemented  measures 
mentioned  above.  Those  aspects  will  therefore  not  fall  under  a  specific  policy  option  or 
action. The harmonisation of the interface on the end device will be based on international 
and European standards which are developed by industry. Those standards will represent a 
basis  to  strengthen  the  enforcement  in  the  field,  as  it  will  provide  a  benchmark  against 
which  enforcement  can  take  place.  In  order  to  keep  track  of  the  technological 
developments,  any  regulatory  option  descried  in  section  5.2  will  be  accompanied  by  an 
empowerment to issue delegated acts to keep the pace of possible future standards/revision 
of existing standards  with  common solutions.  Those delegated acts,  as  common practice, 
will include a transitional period to allow industry and consumers to smoothly migrate to 
the new common solutions. 

28 

 
5.1.  What is the baseline from which options are assessed? 

Policy Option 0 is the current baseline scenario of the revision, against which the potential 
impacts  of the policy options are measured. This policy option consists in  no EU action, 
meaning the preservation of the “status quo”, as described in section 2. Under this option, 
the  MoU  of  2018109  –  a  voluntary  action  from  the  manufacturers  –  will  remain  the  only 
voluntary tool through which signatories “declare their commitment to continue to enable 
smartphones  to  be  charged  through  a  common  charging  interface  in  fulfilment  of  the 
requirement  of  interworking  between  the  power  source  and  the  smartphone  while 
leveraging  the  ability  of  USB  Type-C™  to  be  the  common  charging  interface  for  other 
types  of  portable  electronic  equipment  as  mentioned  in  the  Radio  Equipment  Directive 
2014/53/EU  (article  3.3a).  In  furtherance  of  this  end,  signatories  agree  to  gradually 
transition to the new common charging solution for Smartphones based on USB Type-C”. 
However, this MoU: 

  “is limited to wired charging solutions for Smartphones”; 
  allows the following to “be considered compliant with this MoU:  

o  a cable assembly that is terminated on both ends with a USB Type-C plug;  
o  a cable assembly that is terminated on one end with a USB Type-C plug and 
has  a  vendor-specific  connect  means  (hardwired/captive  or  custom 
detachable) on the opposite end;  

o  a  cable  assembly  that  sources  power  to  a  USB  Type-C  connector  from  a 

USB Type-A connector”. 

  allows that “Smartphone models compliant with the technical requirements as laid 

out in the first MoU (5 June 2009) may still be sold”110; 

  “shall  not  preclude  innovation  (for  example  in  Smartphone  and  External  Power 
Supply designs, battery and charging technologies, interfaces, adaptors, cables, or 
improved charging performance)”. 

The MoU will only cover, in a voluntary manner, the end-device connector described at the 
beginning  of  this  chapter.  The  MoU  does  not  include  any  of  the  other  four  specific 
objectives  and  currently  there  is  no  consideration  to  launch  a  new  MoU.  Therefore,  its 
implementation  will  not  lead  to  full  interoperability.  Additionally,  manufacturers  will  be 
able  to  sell  their  mobile  phones,  or  other  similar  devices,  bundled  or  unbundled  from  a 
charger.  

109 https://www.digitaleurope.org/wp/wp-content/uploads/2019/01/2018.03.20-
MoU%20on%20the%20future%20of%20Common%20Charging%20Solutions%20(1)%20(1)%202.pdf  
110 “http://ec.europa.eu/DocsRoom/documents/2417/attachments/1/translations. Smartphones compliant with 
the  first  MoU  include,  but  are  not  necessarily  limited  to,  those  chargeable  through  a  cable  assembly  that 
sources power to a USB Micro-B connector (with an adaptor made available if needed) as set forth therein” 

29 

 
                                                           
5.2.  Description of the policy options 

The following packages have been considered as viable alternatives that will be subject to 
detailed assessment.  

Table 5 - Description of policy options  

Policy 
Option 

Harmonisation of 
the end-device 
connector 

Option 0 
Option 1 
Option 2 
Option 3 
Option 4 
Option 5 

No action  
Mandatory 
No action 
No action 
Mandatory 
Mandatory 

Support of the relevant charging 
protocol on the end-device and 
informing consumers about 
charging performance 
No action 
No action 
Mandatory 
Mandatory 
Mandatory 
Mandatory 

Making available on 
the market at least 
unbundled solutions 

No action 
No action 
No action 
Mandatory 
No action 
Mandatory 

For  all options,  there would  be then an additional  consideration to  either  a narrow scope 
(mobile  phones  only)  or  a  broad  scope  (mobile  phones,  tablets,  cameras,  earbuds  and 
headphones,  headsets,  handheld  videogames  consoles,  portable  speakers,  e-readers, 
smartwatches  and  fitness  trackers).  It  is  recalled  that  when  no  action  is  foreseen  under 
“Harmonisation of the end-device connector”, the MoU 2018 keeps applying.  

Policy  Option  0  –  No  action:  This  policy  option  entails  no  change  to  the  current 
regulatory framework and to the ways of work.  

Policy  Option  1:  This  option  builds  on  the  baseline  and  adds  the  measure  to  mandate  a 
harmonised interface USB type C at the end-device’s side.  

Policy  Option  2:  This  option  builds  on  the  baseline  and  adds  the  measure  to  mandate 
interoperability with suitable USB communication protocol at radio equipment side. It also 
adds  as  a  flanking  measure  the  measure  to  mandate  manufacturers  to  inform  consumers 
about the charging performance of the device. 

Policy  Option  3:  This  option  builds  on  the  policy  option  2  and  adds  the  measure  to 
mandate  manufacturers  to  make  available  on  the  market  at  least  unbundled  solutions. 
Manufacturers will be left with the opportunity to supply also a bundled version. 

Policy Option 4: This is a combination of the measures in policy options 1 and 2.  

Policy Option 5: This is a combination of the measures in policy options 1 and 3. 

5.3.  Discarded options and measures 

Different  measures  discussed  at  the  beginning  of  this  section  were  either  discarded  at  an 
early  stage,  or  during  the  development  of  this  initiative,  for  the  considerations  below. 
These were: 

30 

 
  A new MoU or a voluntary approach  

Under this option, industry would have improved the MoU of 2018, through a revamped 
request  of  the  Commission,  consumers  and  European  Parliament,  possibly  expanding  its 
scope  or  applicability  (e.g.  to  uniformity  of  performance  or  information  to  users).  It  is 
recognised  that  the  voluntary  approach  of  2009  has  initially  been  successful  in  reducing 
significantly the number of charging solutions. However, to reach a new MoU took 9 years 
and the outcome has been deemed unsatisfactory to meet the policy objectives as a result 
of the opposition of major market players. Actually, the MoU of 2018 has been identified 
to allow even more solutions that the one of 2009, with a reduced commitment. Amongst 
others,  the  issue  of  performance  was  explicitly  not  addressed,  despite  the  problem  being 
already  present  at  the time of  adoption of the  MoU.  It  is  therefore highly unlikely that a 
new satisfactory MoU can be agreed and effectively implemented.  

  Non-action  on  the  charging  protocol  or  unbundling  whilst  mandating 

information to consumers 

Interoperability  with  a  shared  communication  protocol  is  a  pre-requisite  to  achieve  a 
coherent unbundling of the charger as well as to  provide pertinent  charging performance 
information to the consumers. 

  Considering “the support of the relevant charging protocol on the end-device” 
and  “informing  consumers  about  charging  performance”  as  two  separate 
measures 

It would not be coherent to mandate equipment to be interoperable with chargers (up to the 
maximum  power  the  device  supports)  without  providing  the  related  information  to 
consumers, who would have to match devices and chargers.  

  Considering  “unbundling”  without  “the  support  of  the  relevant  charging 
informing  consumers  about  charging 

protocol  on  the  end-device  and 
performance”  

It would not be coherent to mandate unbundling of EPS leaving the consumers uninformed 
on the charging requirements and performance of the devices they plan to buy. 

  Ad-hoc solutions (e.g. adaptors) for devices with proprietary interfaces 

This option would consist in obliging manufacturers of devices with proprietary interfaces 
to include in the box (i) exclusively a cable with a common connector with an adaptor from 
common  to  proprietary  interface  or  (ii)  an  adaptor  from  the  proprietary  interface  to  a 
common  interface.  Both  these  suboptions  was  discarded  as  they  would  not  solve  the 
problem  of  full  interoperability  of  chargers  with  devices  and  would  not  reduce  the 
inconvenience  to  some  users  at  the  expense  of  inconvenience  to  other  users.  In  addition, 
negative  environmental  impacts  would  have  resulted  from  the  need  to  supply  adaptors 
which would not be used or easily lost. This was confirmed through the results of Public 

31 

 
Consultation suggesting that consumers are not keen on adaptors111, with only 25% stating 
they would be satisfied with this option.  

  Harmonisation of EPS 

Full harmonisation of the EPS (e.g. in terms of interfaces and performance) was discarded 
after  the  report  of  the  study  on  Common  Chargers  of  Portable  Devices112:  all  cables  are 
detachable,  and  only  two  interfaces,  both  non-proprietary,  are  present  on  the  EPS  (USB 
type A and type C) due to an ongoing transition. The benefits of attempting to accelerate 
this  transition  risks  to  make  obsolete  a  significant  amount  of  existing  EPS  and  charging 
infrastructure  (e.g.  at  the  airports,  on  trains,  in  vehicles,  etc),  with  potential  negative 
consequences and costs in terms of both consumers and e-waste. In addition, chargers are 
not in the scope of the RED. However, it is acknowledged that measures on the EPS side 
would usefully complement this initiative and the need of further action on the EPS side is 
being addressed in parallel (see Section 1 and Annex 6).  

  Unbundling cables 

Under  this  option,  the  unbundling  would  not  concern  the  EPS  only  but  also  the  cable. 
Amongst all equipment for charging, cables are the product that consumers purchase most, 
counting for approximately 50% of the sales113. This is due to different reasons, as cables 
(i) break more frequently than EPS, (ii) can be used for other purposes than charging (e.g. 
for transferring data to a laptop), (iii) can connect to existing dedicated charging ports (e.g. 
in airports, on trains, in hotels, etc)). As, in addition to the fact unbundling of cables will 
results in a higher consumer inconvenience, cables have a reduced impact on e-waste with 
respect to EPS (see table 4.4 and 4.5 of annex 4), this option was not retained.  

  Making available on the market only unbundled solutions  

This  option  aimed  to  have  on  the  Union  market  exclusively  mobile  phones  sold  without 
chargers.  Surveys  of  consumers  showed  that  around  80%  of  consumers  still  think  it  is 
important to find a charger (EPS and cable) in the box of the device they buy, which is also 
the  result  of  the  reduced  information  passed  to  consumers  (see  section  2.2).  In  addition, 
according to  the stakeholders’ feedback, manufacturers  are  also  most likely to  offer only 
one packaging solution (unbundled) on the market if unbundling is mandated. Therefore, 
this option has been disregarded.  

  Regulatory options on wireless charging 

111 idem and https://data.europa.eu/doi/10.2873/788086  
112 https://op.europa.eu/en/web/eu-law-and-publications/publication-detail/-/publication/c6fadfea-4641-11ea-
b81b-01aa75ed71a1 
113 Figure 6-2 of the study in https://www.digitaleurope.org/wp/wp-content/uploads/2019/12/RPA-Study-
Common-Charger-2.0-final.pdf 

32 

 
                                                           
Wireless charging is a new technology. The technology is not at a mature stage and it is too 
early to assess if and to what extent it could become a source of consumer inconvenience 
in  the  future.  Nevertheless,  there  is  no  indication  of  an  obvious  problem,  or  a  strong 
demand  from  consumers  or  stakeholders  for  a  common  wireless  charger.  A  separate 
technical  study  confirmed  a  low  fragmentation  at  the  moment  and  a  good  level  of 
interoperability  among  the  different  solutions  for  each  product.  Furthermore,  wireless 
charging can be affected by the shape of the device to charge (charging pads for earbuds 
and  other  small  devices  have  very  specific  shapes  that  have  to  match  the  product  to 
‘connect’  with  embodied  batteries).  Manufacturers  are  currently  working  to  a  level  of 
harmonisation  and  interoperability  of  this  technology.  The  Commission  will  keep 
monitoring  the  situation,  leaving  the  need  to  act  to  a  future  assessment.  This  initiative, 
however, will refine the empowerments to act on this type of charging. 

  A scheme for labelling the equipment 

Finally,  it  would  not  be  appropriate  to  pursue  the  option  to  set  in  place  environmental 
information. Consideration of elements related to the chargers is being explored in ongoing 
Ecodesign/Energy  Labelling studies (on mobile phones, tablets  and laptops); pending the 
results  of  those,  taking  action  at  this  stage  appears  unrealistic  but  to  consider  it  in  the 
future, specifically in the context of ecodesign developments114. 

6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

This  section  describes  the  impact  of  different  options  as  regards  the  wired  charging 
solutions. As for the wireless charger the status quo will be preserved, there is no further 
analysis that will be run in this section. Legal and policy considerations, however, will be 
put forward in section 8.1. 

Economic,  social  and  environmental  impacts  were  considered  in  assessing  the  policy 
options. In more detail, it was sought to have a quantitative analysis, wherever possible, of 
the  following  aspects:  environmental  impacts,  consumers’  perspective  and  convenience, 
effects  on  the  industry  in  particular  as  concerns  costs  and  employment.  Other  significant 
impacts such as impact on SMEs, innovation, competitiveness were also analysed. 

on 

the 

EC 

See 

impact 

inception 

assessments 

114 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12797-Environmental-impact-of-
mobile-phones-and-tablets-Ecodesign)  and  Energy 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12798-Environmental-impact-of-
mobile-phones-and-tablets-Energy-Labelling).  The  preparatory  study  on  potential  Ecodesign  and  Energy 
Labellling  requirements  for  mobile  phones  and  tablets  confirmed  the  relevanvce  of  the  aspects  related  to 
environmental  information,  in  particular  related  to  the  manufacturing  phase.  However,  this  appears  of 
complex feasibility within the Ecodesign framework, with the aim to have reliable, comparable and verifiable 
information. 

labelling  of  mobile  phones  and 

tablets  (URL: 

requirements 

Ecodesign 

(URL: 

33 

 
                                                           
There  are  various  uncertainties  when  projecting  forward  and  assuming  market  and 
technological  developments  into  the  future,  and  also  for  the  other  assumptions  that 
underpin the market model. Whilst some assumptions such as charger profiles, e.g. weight, 
price, etc, will see scaling effects proportional to the changes made, others can have more 
complex effects. The model was examined for variables for which sensitivity checks would 
be possible and where variance in the variable/assumption could have an important impact 
on  the  results.  Also  it  was  considered  triangulation  of  data  to  validate  model  results,  for 
example in terms of quantities of charger units, it provides good confidence that the model 
overall settings are robust as the number of EPS and cables in the stock, compared to the 
survey  reported  EPS  and  cables  owned  by  consumers  correspond  closely.  Feedback 
received  from  stakeholders  were  complemented  through  desk  research,  where  possible. 
Efforts  were spent  to  get  reliable quantitative data.  In many  cases stakeholders could  not 
provide precise costs or data, as reported in the different sections. Where possible, in order 
to remedy to this uncertainty, a sensitivity analysis was performed. For a full description of 
the limitation of the analysis and details concerning the methodology, we refer to Annex 4. 

It is specifically noted that limited EU industries are present in the sector, hence the related 
impacts lacked robust data. Further in this report, when referring to the industry, it is meant 
to refer to manufacturers of mobile phones and/or other portable devices, manufacturers of 
chargers,  manufacturers  of  accessories,  and  wholesalers  all  together.  For  all  mandatory 
options a transitional period  will be observed, providing manufacturers sufficient  time to 
adapt  to  the  new  requirements.  It  is  noted  that  the  selected  common  interface115  and 
communication  protocols116  have  been  standardised  at  the  international  level,  are  widely 
available  and  also  manufacturers  of  mobile  phones  with  proprietary  interfaces  are  using 
them on different products. 

It  is  noted  that  most  of  the  companies  in  the  supply  chain  of  mobile  phones  and  other 
portable  devices  and  their  chargers  are  located  outside  of  the  EU.  There  are  few 
manufacturers  of  mobile  phones  headquartered  in  the  EU  (notably,  HMD,  Nokia,  BQ, 
Wiko, and Fairphone). None of them use proprietary interfaces in their phones. Fairphone 
is the only SME, whose products come already without chargers. As regards manufacturers 
of chargers, in the EU there are around 10,000 companies manufacturing “other electrical 
equipment” in the EU (NACE 2790), of which it is estimated that around 1% (100 firms) 
manufacture power supply units for telecommunication apparatus117. As in the next options 
the  impacts  on  the  EU  industry  is  marginal,  it  is  considered  that  there  is  no  impact  on 
European employment and it will not be repeated further. 

Regulations  that  affect  the  overall  number  of  sales  of  EPS  and  cables  in  the  EU  would 
mainly  affect  the  firms’  turnover  and,  therefore,  may  have  wider  implications  on 

115 USB type C 
116 USB Battery Charging and Power Delivery 
117 It is estimated that their turnover in 2020 was 154 million EUR (including only turnover from sales of 
chargers). 

34 

 
                                                           
production. These effects have been modelled (see Annex 4) and differences in  revenues 
between the policy options and the baseline have been reported. 

Specifically for certain technical aspects of the measures described in section 5.2, namely 
the  harmonisation  of  the  end-device  connector  and  the  support  of  the  relevant  charging 
protocol  on  the  end-device,  doubts  that  were  occasionally  put  forward  concerned  the 
creation  of  a  non-tariff  barrier,  with  specific  respect  to  the  Agreement  on  Technical 
Barriers to Trade118. In that respect, it has to be noted that any regulatory option will ensure 
that (i) imported products  will not be subject  to a stricter regulation  than products  which 
are EU-manufactured, (ii) the requested interoperability aspects will be based on specific 
clauses  of  international  and  manufacturers’  drafted  standards,  (iii)  those  clauses  will  be 
necessary to fulfil the policy objectives. This is of the utmost importance, recalling that the 
reference to international and manufacturers’ driven standards is presumed not to create an 
unnecessary obstacle to international trade as per the Agreement itself.  

6.1.  Policy Option 0 – baseline scenario 

As  described  in  section  2  and  Annex  5,  the  current  situation  is  characterised  by  the  co-
existence  of  different  interfaces  and  proprietary  charging  solutions  as  regards  both  the 
connectors  and  the  communication  protocols.  Unbundling  of  EPS  is  taking  place  for 
certain models of mobile phones, whilst no information is given to the consumers on the 
charging  requirements  of  the  equipment.  The  situation  for  small  electronic  devices  other 
than mobile phones is also fragmented. 

Stakeholders’  views  on  the  policy  option:  Manufacturers  support  this  option.  EU  MS 
have  different  views,  with  a  majority  not  in  favour.  The  European  Parliament  and  the 
consumers’ associations do not support this option.  

6.2. 

Policy Option 1 – Harmonisation of the end-device connector 

This option builds on the baseline and adds the measure to mandate a harmonised interface 
USB  type  C  at  the  end-device’s  side.  This  option  requires  that  manufacturers  of  mobile 
phones with a proprietary connector would change them to a common one. The transition 
from  the  old  common  connector  (USB  type  B)  to  the  new  one  (USB  type  C)  will  be 
accelerated.  The  effect  of  this  elimination  is  observed  after  2024,  which  is  a  timeline 
consistent with the legislative one. 

Economic impacts: 

Impact  on  economic  operators:  The  manufacturers  of  mobile  phones  using  a  proprietary 
connector  will  need  to  ensure  that  charging  via  USB  Type  C  is  possible  for  all  new 
products from the date of implementation of the changes in the Directive. This might entail 

118 https://www.wto.org/english/docs_e/legal_e/17-tbt_e.htm  

35 

 
                                                           
some one-off  adjustment costs. There is  only  one manufacturer who will have to  change 
the mobile phones to adapt them to the common interface. Other manufacturers typically 
use  the  common  interface  in  devices  in  the  middle-top  end  of  the  segment  and  they  are 
progressively adopting it in devices in the lower end of the segment (Micro USB type B to 
be phased out by USB C at 95-99% by 2024 under the baseline).  

As regards the related costs, it was not possible to retrieve the following one-off costs: (i) 
whether the changes would concern the connector only as assembled on the board or they 
would concern other changes and which would they be, and (ii) to which extent the related 
costs  have  not  been  yet  sustained  (e.g.  other  products  from  those  manufacturers  already 
have a common interface). As regards administrative burden on businesses, there is already 
a standard in place and manufacturers with a common interface run tests on it as a matter 
of internal quality control. The compliance costs are consequently already part of the BaU. 
As discussed at the beginning of Section 6, there are a few EU manufacturers in the sector, 
some  of  which,  SME  in  primis,  already  use  a  common  interface  in  their  products.  Even 
taking  into  account  the  supply  chain119  of  major  international  manufacturers,  impact  on 
SMEs is negligible. As consumers will buy less cables (4.8% reduction in sales compared 
to  the  baseline),  the  profits  for  manufacturers  of  mobile  phones  and  accessories  with 
proprietary interfaces are expected to decrease by 8.4% after 2023. The overall impact for 
the worldwide industry with this option is a reduced turnover by 139 million EUR120 yearly 
(-8.2%) while the impact on EU industry will be limited to a loss of 18 million EUR yearly 
(-8.5%). The consequences on distributors and retailers until the point of sale will cause for 
them  a  reduction  of  turnover  of  271  million  EUR  yearly  (-9%).  In  this  losses  are  also 
expected  incomes  from  royalties121.  These  ones  are  difficult  to  assess  due  to  the  lack  of 
data  from  the  manufacturers  and  therefore  difficult  to  highlight.  If  not  appropriately 
mitigated122,  this  option  could  potentially  have  a  negative  effect  in  terms  of  reducing 
possible future innovation in phone connectors (see section 8.1).  

Impact  on  competitiveness  and  innovation:  one  of  the  arguments  in  the  interviews  from 
manufacturers  using  proprietary  connectors  is  that  their  connectors  allow  certain 
advantages  (e.g.  they  are  lighter  or  thinner)  and  this  may  be  reflected  on  the  technical 
characteristics of their products. Hence, they argue that harmonising the connector would 
hamper  innovation  and  it  would  likely  damage  their  competitive  position.  In  any  case, 
recent developments show that mobile phones with the common interface can be actually 
thinner123  than  those  with  a  proprietary  interface124.  It  is  also  to  be  considered  that  those 

119  The  most  affected  manufacturers  will  be  Apple  and  their  supply  chain.  Most  of  their  supply  chain  is 
comprised of multinational organisations with a few basis in the EU.  
120 see table 29 of https://data.europa.eu/doi/10.2873/788086 
121 https://data.europa.eu/doi/10.2873/788086 
122 See section 8.1 on the mitigation of this risk 
123 e.g. 6.81 mm as in the Xiaomi Mi 11 Lite https://www.mi.com/global/product/mi-11-lite/specs 
124 e.g. 7.3 mm as in the Apple iPhone SE (2020) https://www.apple.com/iphone-se/specs/ 

36 

 
                                                           
manufacturers are already migrating for certain products to the USB type C connector in 
their new tablets.  

Impact on Public Authorities: Public authorities have not, so far, enforced the presence of a 
common  connector.  The  costs  of  checking  its  presence  are  believed  to  be  negligible  and 
the costs for checking its safety are already currently performed, so the costs are expected 
to  be  negligible.  There  will  be  no  additional  impact  compared  to  the  baseline  for  public 
authorities. In general, as also the other options can be verified by the Authorities either via 
inspection or via conventional tests on the equipment, the impact on the public Authorities 
is considered to be included already in the BaU, and hence negligible. 

Social impacts: 

Consumers convenience: The elimination of the need for proprietary connectors and cables 
will give a substantive economic gain to consumers. In fact, market share show that these 
type of cables represents 17% of the stock in the baseline, and can be up to 1.8 times more 
expensive than USB Type C to USB type C cables and 2.6 times more expensive than USB 
Type  A  to  USB  Type  C  cables.  Consumer  survey  also  reveals  that  a  broken  cable  is  the 
main reason for buying a new mobile phone charger (36% of cases). On average users of 
proprietary cables bought per capita 0.73 cables in the last 24 months, whereas the overall 
average for all brands is 0.51 cables. Consumers will buy less cables and the average price 
that consumers pay for the cable will decrease because of the harmonisation, resulting in a 
increase of the average  money saved  yearly by  consumer of 549 million  EUR (8.4%)125. 
This is the result of two effects, i.e. the removal of the necessity for proprietary connectors, 
which are more expensive than the common ones, and the reduction in the number of sold 
EPS and cables. Two significant sources of consumers inconvenience (see section 2.1) i.e. 
no access to a compatible charger and confusion about which electronic devices work with 
which  charger  works  will  be  eliminated  through  the  possibility  to  use  common  chargers 
with all devices within scope. 

Under  this  option,  users  of  equipment  with  proprietary  connectors  will  benefit  from  a 
reduction  of  price  of  chargers,  cables  and  accessories,  thanks  to  the  absence  ofroyalties 
which are passed on to the consumers. At the same time however, existing accessories can 
be connected to devices through proprietary connectors only. EPS are not in this category 
of  accessories,  as  they  are  already  interoperable  through  appropriate  cables,  which  are 
distributed in the retail boxes almost in all cases. As regards those accessories, it is noted 
that (i) when those manufacturers switched to the USB type C connector on newer devices 
(e.g.  tablets),  consumers  did  not  report  major  inconvenience  and  (ii)  those  accessories 
became  wireless  in  the  last  years,  therefore  the  market  itself  has  already  limited  the 
inconvenience due to a change of the physical connectors. In the absence of precise data it 
is  therefore not  possible to  quantify at  which moment in  time the consumers will have a 

125 see table 12 of https://data.europa.eu/doi/10.2873/788086 

37 

 
                                                           
break even between the (temporary)  costs incurring from  the change of interface and the 
(permanent) reduction of prices. 

Product Safety and Illicit Markets: this option could lead to a small reduction of the sale of 
substandard  cables.  According  to  the  consumer  panel  survey,  users  of  phones  with 
proprietary connectors126 purchase slightly (approx. 27%) more stand-alone chargers than 
users  of  phones  with  USB  connectors.  As  regards  the  safety  of  in-the-box  chargers,  a 
common  universal  USB  Type-C  connector  at  the  phone  end  would  have  no  impact  on 
product safety. Safety risks from in-the-box cables are negligible to begin with, and there is 
nothing to suggest this option would make any difference in this respect. 

Environmental impacts: 

The  environmental  impacts  from  the  fact  that  USB  Type  C  cables  and  connectors  are 
heavier (by 21.6% to Lightning and 237% to USB micro-B) are bigger than the reduction 
of standalones sales of cables will have the following net overall effects:  

  A  marginal  increase  in  the  materials  used,  this  represents  a  1.5%  yearly  increase 
compared  to  the  baseline  (329  tonnes).  For  this  policy  option,  only  minimal 
changes  between  2024-2030  per  material  type  are  observed  compared  to  the 
baseline  (2%  additional  decrease  of  both  the  amount  of  the  copper  and  stainless 
steel used); 

  A  nearly  negligible  effect  in  e-waste  generated  and  represents  a  0.8%  yearly 
increase compared to the baseline (155 tonnes). The same trend is observed in the 
amount of untreated and recycled e-waste (0.8% and 0.9% increase to the baseline, 
respectively); 

  A  small  increase  in  GHG  emissions  that  represents  a  1.6%  yearly  increase 

compared to the baseline (18 tonnes).  

The  environmental  impacts  of  disposing  all  accessories  with  proprietary  interfaces,  and 
their replacement by USB-C is unfortunately difficult to estimate because, as highlighted 
by  the  surveys,  consumers  tend  to  hold  to  the  out-of-use  accessories  quite  a  long  time 
before disposing them.  

Suboption: broad scope of the initiative 

As  regards  to  the  extension  of  the  scope,  the  study  shows  that  tablets,  headphones, 
headsets,  handheld  videogame  consoles,  portable  speakers  and  cameras  are  suitable 
devices to be incorporated in the scope as they share a similar situation as mobile phones 
with  regards  to  the  connector.  As  they  mostly  use  the  USB  type  C,  the  accelerated 
transition  would  have  minor  negative  effects  on  the  environment  but  would  increase 
further the savings for consumers, while also decreasing the profit for the industry. 

126 e.g. Lightning 

38 

 
                                                           
Therefore, extending the scope to other devices was deemed not to provide any additional 
positive impact either because it is not the best technical option and/or the negative impacts 
would  clearly  overweight  the  positive  impacts.  The  impacts,  when  looking  at  the  data 
available  for  tablets,  cameras,  and  headphones,  evolve  to  the  following  figures  when 
comparing to the baseline (refer to Annex 4 for more details):  

  The  turnover  of  worldwide  industries  decreases  of  180  million  EUR  yearly,  18 
million  for  the  EU  industries,  and  decrease  of  261  million  EUR  yearly  for 
distributors and retailers. 

  The saving to consumers will be in the order of 620 million EUR yearly; 
  The material  use increases by 524 tonnes more  yearly, the e-waste by 280 tonnes 

yearly and GHG emissions by 25 ktCO2 yearly. 

Stakeholders’ views on the policy option: Manufacturers do not support this option, nor 
the suboption.  EU MS have different  views, with  an overall majority in  favour, although 
they  would  prefer  it  in  combination  with  other  measures.  The  European  Parliament  and 
consumers’  associations  would  welcome  this  Option  but  would  prefer  it  in  combination 
with other measures. 

6.3. 

Policy Option 2  – Support of the relevant charging protocol  on the  end-
device and informing consumers about charging performance 

Under this option, the radio equipment will be mandated to be interoperable with suitable 
USB  communication  protocol  and  manufacturers  will  be  required  to  inform  consumers 
appropriately. Equipment which only requires reduced power inputs (5W or less) will not 
be mandated to support more expensive solutions, in line with the content of the standard. 
In more detail, 

  As  regards  the  information  to  consumers,  there  are  two  data  that  would  allow 
consumers  to  understand  the  charging  needs  of  new  devices.  These  are  (i)  the 
maximum  power  that  the  device  can  take  and  (ii)  the  support  to  fast  charging. 
Under this option, these data would be requested to appear in in a clear, intelligible 
and  visual  manner  on  the  retail  box  -so  to  allow  consumers  to  make  informed 
decisions.  This  information  will  be  complemented  on  the  EPS  side  through  the 
related  eco-design  initiative  and  will  allow  consumers  to  match  them  as 
appropriate. 

  As  regards  the  charging  protocol,  more  and  more  EPS  are  supporting  USB  PD 
charging  protocols,  with  increased  versatility.  On  the  one  hand,  consequently, 
devices  will  be  requested  to  support  (up  to  the  maximum  power),  the  USB  PD 
charging  protocol.  On  the  other  hand,  however,  manufacturers  will  not  be 
prevented to develop on top of this common protocol, proprietary technologies for 
a competitive advantage. In other words, manufacturers will have to include at least 
the  standardised  fast  charging  protocol  (USB  PD)  but  will  be  allowed  to  include 
other technologies provided that minimum interoperability requirements (as in the 

39 

 
USB PD standard) are guaranteed. This will allow to achieve the policy objectives 
on interoperability of the charging performance, whilst not preventing innovation. 

Economic impacts: 

Impact on economic operators: According to information provided by interviews, the cost 
for manufacturers of including USB PD at the device end would be a minor increase (0.6 
EUR per phone). It would concern manufactures currently using proprietary fast charging 
protocols not compatible with USB PD or not supporting fast charging at all, around 20% 
of the volumes  of the total market.  Recalling that  260 million  phones are sold  in the EU 
yearly,  this  would  account  for  30  million  EUR.  Interviewed  stakeholders  foresee  that 
phones currently using Quickcharge 3 will have naturally transitioned to later versions of 
Quickcharge compatible with USB PD, with costs therefore falling under the Business as 
Usual (BaU). This option will ultimately result in a reduction of standalone sales of EPS 
(4%  reduction  by  2030  compared  to  the  baseline)  and  cables  (3.1%  reduction  by  2030 
compared  to  the  baseline).  This  turns  into  a  loss  of  revenues  for  worldwide  industries 
estimated  at  32  million  EUR  yearly  between  2024  and  2030  which  correspond  to  a 
decrease  of  1.9%  compared  to  the  baseline.  The  negative  impact  on  the  turnover  of  EU 
industries is estimated at 7 million EUR yearly (corresponding to a decrease of 3.1%). See 
also  annex 4 for details.  The consequences on distributors and retailers until  the point of 
sale will cause for them a reduction of turnover of 105 million EUR yearly (-3% compared 
to the baseline). 

Adding the measure on providing information to consumer about the charging performance 
as  a  flanking  measure  is  expect  to  have  negligible  costs.  In  fact,  under  the  RED, 
manufacturers are already obliged to provide information (Article 10(8)). Only the costs to 
make it more visible are to be accounted, but – if sufficient time is provided – this will fall 
under the business as usual, as new packaging and new instructions are always designed by 
the industry. 

Impact on competitiveness and innovation: The impact on competition will be limited, in 
fact,  most  of  the  phones  and  chargers  already  ensure  interoperability,  so  this  option  will 
only affect manufacturers that do not provide interoperable devices with the USB PD (see 
fgiure  5.2  in  Annex  5).  However,  some  smaller  cost  may  occur  for  manufacturers  of 
system on a chip127 (SoC), but the battery charging protocol is only a small component of 
the  chip.  It  is  not  expected  that  the  option  would  produce  changes  in  the  distribution  of 
revenue  among  competitors.  For  manufacturers  of  mobile  phones,  the  option  is  not 
expected to generate major changes in the competitive landscape. Manufacturers who want 
to continue offering proprietary fast charging solutions along with USB PD could continue 
to  do  so,  and  consumers  who  value  this  as  a  competitive  advantage.  This  option  might 
affect negatively small firms that produce low-end phones and that would have otherwise 

127 See annex 5 

40 

 
                                                           
continued using USB micro-B connectors and/or USB BC protocol. The size of this market 
is  small  (9%  in  the  baseline  in  2024).  There  will  be  no  impact  on  the  competition  for 
manufacturers  of  chargers  nor  for  retailers  and  distributors.  As  under  this  option, 
manufacturers  can  maintain  their  charging  solutions  in  the  mobile  phone,  as  long  as  the 
common protocol is implemented, no negative impacts on innovation are expected. 

Impact on public authorities: costs for public authorities would be the same as for option 1. 

Social impacts: 

Consumer  Convenience:  The  increased  consumer  convenience  under  this  policy  option 
originates from (i) the switch from slightly more expensive accessories and charger (due to 
charging protocol) to cheaper ones and to the long term reduction  of standalone chargers 
purchased  (3.1%  less  cables  and  4%  less  EPS)  induced  by  the  harmonisation  of  the 
charging protocol, and (ii) the information provided to customer about charging. It would 
enhance the guaranteed interoperability of fast charging, plus ability to charge all phones 
with  the same cables, it  would also  add a minor  benefit in  regard to  the  compatibility of 
charger  due  to  faster  elimination  of  USB  micro-B  connectors,  and  the  measure  on 
providing information to consumer would reduce the confusion about which charger works 
with which devices. 

The improved information will allow consumers to reuse existing chargers, at least to some 
extent.  The  expected  reduced  purchases  would  allow  consumers  to  save  168  million 
EUR128  yearly,  which  is  2.6%  less  compared  to  the  baseline.  See  annex  4  for  detailed 
calculations. 

Product Safety and Illicit Market: This option would lead to a very small decrease in stand-
alone  charger  sales.  This  would  results  in  a  negligible  impact  on  the  sales  of  counterfeit 
and illicit chargers. 

Environmental impacts: 

Also, as discussed in section 2, the switch to more powerful EPS, leads to an increase in 
average  cable  and  EPS  weight  and  consequent  increase  in  materials  used.  In  this  option, 
the offsetting impact  of the option in reducing standalone sales is  slightly lower than the 
weight  increase  effect.  The  overall  reduction  of  standalones  sales  of  cables  (-3.1%)  and 
EPS  (-4%)  slightly  overweighs  the  fact  that  USB  Type  C  cables  and  connectors  are 
heavier, this results in the following net overall effects on the environmental impact:  

  A decrease in the materials used, 173 less tonnes yearly compared to the baseline 
between 2024-2030. This represents a 0.8% decrease compared to the baseline. 
  A  decrease  in  e-waste  generated,  with  50  less  tonnes  yearly  of  e-waste  generated 
compared to the baseline total between 2024-2030. This represents a 0.3% decrease 

128 see table 12 of https://data.europa.eu/doi/10.2873/788086 

41 

 
                                                           
compared  to  the  baseline.  The  same  trend  is  observed  in  the  amount  of  untreated 
and recycled e-waste. 

  A  decrease  in  GHG  emissions,  with  emissions  10  ktCO2e  yearly  lower  than  the 
baseline between 2024-2030. This represents a decrease of 0.9 % compared to the 
baseline. 

Suboption: broad scope of the initiative 

The  direct  impact  induced  by  mandating  the  interoperability  of  the  device  with  USB  PD 
would only be appropriate to apply to devices which can support the power levels therein 
described.  

Because  of  this  proportional  application  and  because  the  USB  PD  has  already  a  wide 
degree of support, the impacts of this option 2 are expected to be very minor.  

An extended scope to tablets, headphones, and cameras, change the different impacts to the 
following figures when comparing to the baseline (refer to Annex 4 for more details):  

  The turnover of worldwide industries decreases to 31 million EUR yearly and stays 
at 7 million EUR yearly for EU industries, and decrease of 105 million EUR yearly 
for distributors and retailers. 

  The consumers will save approximately 166 million EUR yearly; 
  The material use decreases by 130 tonnes less  yearly, the e-waste increases by 12 

tonnes yearly and GHG emissions decreases by 8 ktCO2 yearly. 

As for option 1, handheld videogame consoles and portable speakers, for which data was 
not possible to gather, are assumed to provide a proportional similar impact depending on 
the number of units that are currently sold on the market (see Table 5). 

Stakeholders’  views  on  the  policy  option:  Mobile  phone  manufacturers  support  this 
option  and  suboption  as  a  fall-back  of  Option  0.  EU  MS  would  welcome  additional 
provided  information,  but  the  majority  of  them  would  prefer  this  option  in  combination 
with a common connector. The consumers and the European Parliament do not appreciate 
this option as standalone, but would like to see it in combination with at least option 1.  

6.4.  Policy Option 3 – Unbundled solutions in addition to Option 2 

This option builds on the policy option 2 and adds the measure to mandate manufacturers 
to make available on the market at least an unbundled solution. Manufacturers will be left 
with  the  opportunity  to  supply  also  a  bundled  version.  In  all  cases,  cables  could  still  be 
provided. 

Economic impacts: 

Impact  on  economic  operators:  For  those  devices  that  are  not  already  unbundled,  this 
requires  changing the packaging, adapting the shipment and distribution of phones to the 
new packaging dimensions, and potentially re-negotiating their contracts or changing their 

42 

 
relationships  with  their  EPS  suppliers.  The  most  affected  by  this  option  would  be  EPS 
manufacturers that currently provide the EPS to be sold in the box. For them, it will be a 
one-off cost to sell the charger separately and to arrange the related aspects (e.g. logistics, 
supply chain, etc). The EPS manufacturers would need to steer their their business models 
from  supplying  both  the  device  manufacturer  and  the  general  public  to  supplying  to  a 
greater  extent  the  general  public.  In  that  respect,  it  was  not  possible  to  retrieve  the 
following  data,  which  concern  one-off  costs:  to  which  extent  (i)  manufacturers  are 
planning to unbundle their products and (ii) the related costs (e.g. in designing packages) 
are currently being sustained and hence fall under the BaU. However, the related costs to 
apply these changes can be absorbed in the BaU –as it is reasonable to assume–, given the 
relatively  short  average  lifetime  of  mobile  phone  models  and  as  new  models  are 
continuously developed. Retailers and distributors would benefit from the increased sales 
of  stand-alone  chargers,  from  which  they  would  obtain  higher  margins  than  when  sold 
along with mobile phones. This option has no further administrative or compliance burden 
or costs than the ones exposed in previous option 2. Furthermore, in terms of innovation, 
unbundling has no impact. 

It is estimated that the combination of the measures on harmonizing the charging protocol 
and providing consumer with information about charging performances of the devices with 
unbundling will further incentivise the latter and will lead to a overall decrease of turnover 
for the worldwide industry of 168 million EUR yearly (-9.9% compared to the base line), 
while it is expected that the impact on EU indsutry will be an increase of 18 million EUR 
yearly129 (+8.1% compared to the baseline). The consequences on distributors and retailers 
until the point of sale will produce for them an increase of turnover of 334 million EUR 
yearly (+10.5%). This is the result of 60 million EUR less of turnover each year from EPS 
sold  in  the  box,  combined  with  increase  of  standalones  sales  of  EPS  and  cables 
(respectively +3% and +12.9%). 

On  top  of  the  impact  generated  by  the  measure  on  interoperability  of  communication 
protocol  (option  2),  the  measure  on  mandatory  unbundling  can  have  an  impact  for  those 
manufacturers  investing  and  advertising  proprietary  fast  charging  technologies,  as  they 
could  not  offer  the  complete  solution  in  the  box.  However,  the  degree  of  unbundling 
happening  in  the  baseline  scenario  shows  that  this  measures  will  not  affect  the  entire 
market, but only a fraction of the manufacturers. In addition, it is worth recalling that this 
option  will  not  mandate  all  manufacturers  to  provide  unbundled  solutions,  but  at  least 
unbundled solutions, leaving the freedom to provide both. This will mitigate the impact of 
this  option  for  those  manufacturers  that  may  want  to  keep  providing  bundled  solutions, 
whilst allowing consumers’ choice. 

129 see table 30 of https://data.europa.eu/doi/10.2873/788086 

43 

 
                                                           
Also  in  light  of  the  above,  no  impact  on  innovation  and  competitiveness  is  expected  as 
companies  will  be  able  to  continue  offering  bundled  phones  if  they  consider  it  as 
competitive advantage, but as long as unbundled solutions can be found on the EU market. 

Impact on public authorities: Costs for public authorities would be the same as for option 
2. 

Social impacts 

Consumer  convenience:  Under  this  option,  it  is  expected  that  producers  would  decide  to 
market all their phones unbundled from chargers (as they are obliged to offer at least this 
option  to  consumers).  As  per  the  interviews  of  those  manufacturers  that  are  already 
providing unbundling, the cost of the phone is expected to be discounted by the cost of the 
EPS. As EPS would not come by default anymore with mobile phones, there would be a 
rebound effect in the sales of standalone EPS130. When bought standalone, consumers pay 
the retail price, which is 2.2 times the wholesale price. (see annex 4) The costs generated 
by  unbundling  are  practically  equivalent  to  the  amount  saved  by  the  reduction  of 
standalone sales of EPS and cables from the harmonization of the charging protocol. As a 
result, this will bring no savings for consumers (0% compared to the baseline which is -2 
million EUR yearly131 for the period 2024-2030). See annex 4 for details. This option will 
progressively reduce the stock of chargers in each household but will affect consumers, at 
least in the short term, as the majority of them surveyed expressed a preference for being 
provided with a charger along with a new phone.  

Product Safety and Illicit Market: The unbundling measure would also lead to a very small 
decrease  in  stand-alone  charger  sales.  Combining  the  unbundling  measure  with 
harmonizing the charging protocol would overall result in a negligible impact on the sales 
of counterfeit and illicit chargers. 

Environmental impacts: 

The elimination of the EPS supplied in the box (60 million EPS less each year) surpasses 
the increase in the sales of standalone EPS and cables due to the unbundling of the EPS, 
and the negative effect of heavier interface due from harmonisation. The net effect of this 
policy option, as regard to the environmental impact, is: 

Building on that, the overall net effect (see annex 4 for details) of this policy option is: 

  A decrease in the total materials required, with yearly 1908 tonnes fewer materials 
used compared to the baseline total between 2024 and 2030. This represents a 8.7% 
decrease compared to the baseline. 

130 It is estimated that for each phone sold unbundled, 0.39 standalone EPS are bought. 
131 see table 30 of https://data.europa.eu/doi/10.2873/788086 

44 

 
                                                           
  A  decrease  in  the  e-waste  generated,  with  yearly  729  less  tonnes  of  e-waste 
generated  than  the  baseline  total  between  2024  and  2030.  This  represents  a  3.8% 
decrease  compared  to  the  baseline.  The  same  trend  is  observed  in  the  amount  of 
untreated and recycled e-waste. 

  A significant decrease in GHG emissions, with yearly emissions 136 ktCO2e lower 
than  the  baseline  total  between  2024  and  2030.  This  represents  a  12.1%  decrease 
compared to the baseline.  

Suboption: broad scope of the initiative 

On top  of the effects  described in  option 2, the main environmental and economic direct 
effects of unbundling the different devices would mirror those for mobile phones – though 
the scale would obviously be adjusted to account for the size of the different markets, and 
the  already  existing  unbundling  rates  (for  EPS  only).  The  smaller  the  market,  and  the 
higher the current unbundling rates, the more limited the environmental benefits as well as 
other  impacts.  This  includes  different  effects  on  consumer  convenience,  as  the 
inconvenience  would  be  higher  for  users  of  tablets  (all  of  which  currently  come  with  an 
EPS), but much less so for portable speakers (most of which are already unbundled). 

Given  that  unbundling  of  EPS  already  exists  to  some  extent  in  all  devices,  no  operating 
costs, costs of doing business, costs for public authorities, or impacts on SMEs  would be 
experienced beyond those explained in  for mobile phones. Unbundling would  reduce the 
number of chargers that are sold bundled, hence reducing the profits for manufacturers of 
chargers.  

An extended scope to tablets, headphones, and cameras, change the different impacts to the 
following figures when comparing to the baseline (refer to Annex 4 for more details):  

  The  impact  on  turnover  of  the  worldwide  industries  decreases  further  to  reach 
approximately  238  million  EUR  yearly  while  this  option  is  expected  to  have  a 
positive impact on EU industries of 27 million EUR yearly, and a positive impact 
on distributors and retailers turnover of 511 million EUR yearly; 

  The costs to consumers will be increase roughly by 35 million EUR yearly; 
  The material use decreases by 2 566 tonnes less yearly, the e-waste decreases by 1 

048 tonnes yearly and GHG emissions decreases by 179 ktCO2 yearly. 

As for option 1 and 2, handheld videogame consoles and portable speakers, for which data 
was not possible to gather, are assumed to provide a proportional similar impact depending 
on the number of units that are currently sold on the market (see Table 5). 

Stakeholders’  views  on  the  policy  option:  Manufacturers  would  support  this  option,  or 
the suboption, as a fallback of options 0 and 2. The majority of EU MS would support it, 
although many would require to adopt a common connector as well. The consumers do not 
appreciate  this  option,  (i)  as  it  does  not  deliver  a  common  connector  and  (ii)  being 
unbundling not preferred by their majority. The European Parliament would not welcome 
this option without a common connector. 

45 

 
6.5. 

Policy Option 4 – Charging interoperability in addition to Option 1 

This  option  combines  the  mandatory  measures  of  options  1  and  2.  We  refer  to  those 
sections for a description of the standalone impacts and below only the combined effects of 
these two measures are  described. The overall impacts  of this package  would be slightly 
smaller than the sum of the impacts of options 1 and 2 individually. This is because both of 
these options  entail  the replacement  of all remaining USB micro-B  connectors in  phones 
with  USB  Type-C  connectors  (and  the  corresponding  connectors  at  the  device  end  of 
cables),  speeding  up  the  transition  process  that  is  already  ongoing,  but  will  not  be  fully 
completed under the baseline scenario by 2024. 

Economic impacts: 

Impact on economic operators: As discussed in option 1, certain manufacturers of mobile 
phones using a proprietary connector will need to ensure that charging via USB Type C is 
possible  for  all  new  products  from  the  date  of  implementation  of  the  changes  in  the 
Directive. As discussed in option 2, the cost for manufacturers of including USB PD at the 
device end would be a minor increase (0.6 EUR per phone). It would concern around 20% 
of the volumes  of the total market.  Recalling that  260 million  phones are sold  in the EU 
yearly, this would account for 30 million EUR. The reduction of standalone sales of EPS is 
also as for Option 2, but the combined loss of revenues is estimated at 173 million EUR 
yearly132  between  2024  and  2030  which  correspond  to  a  decrease  of  10.2%  compared  to 
the  baseline.  The  negative  impact  on  the  turnover  of  EU  industries  is  estimated  at  25 
million EUR yearly (corresponding to a decrease of 11.6%). See also annex 4 for details. 
The consequences on distributors and retailers until the point of sale will cause for them a 
reduction of turnover of 374 million EUR yearly (-11.8%). 

Impact on public authorities: costs for public authorities would be the same as for option 1. 

Social impacts:  

Consumer convenience: The elimination of the need for proprietary connectors and cables 
will give a substantive economic gain to consumers, as discussed in option 1. Further gain 
will  come  from  the  savings  and  the  information  as  in  option  2.  The  consequent 
combination of effects will therefore allow consumers to save 720 million EUR133 yearly, 
which is 11% less compared to the baseline. This effect overweighs by far the higher cost 
of upgrading the connector to USB Type-C and the charging protocol to USB PD. 

Product  Safety  and  Illicit  Market:  The  combined  effect  is  estimated  to  produce  a  4% 
reduction  in  stand-alone  EPS  sales,  and  7.9%  reduction  in  stand-alone  cable  sales.  This 
would result in a reduction of substandard and/or counterfeit sales on a similar scale, and 
thus to a very small reduction in product safety risks. 

132 see table 30 of https://data.europa.eu/doi/10.2873/788086 
133 see table 30 of https://data.europa.eu/doi/10.2873/788086 

46 

 
                                                           
Environmental impacts: 

As for Option 1, the fact that USB Type C cables and connectors are heavier than others 
compensates the gain from the reduction of standalones sales of cables and EPS, results in 
net overall effects on the environmental impact:  

  A  small  decrease  in  materials  used  from  2023  onwards:  around  140  less  tonnes 
yearly compared than the baseline. This represents a 0.6% decrease. As for option 
1, only minimal  changes per material  type are observed  compared to  the baseline 
(Section 2 and Annex 4). 

  A  small  decrease  in  the  e-waste  generated  from  2023  onwards:  27  tonnes  yearly 
lower  than  the  baseline.  This  represents  a  0.1%  decrease.  The  same  trend  is 
observed in the amount of untreated and recycled e-waste. 

  A small decrease in GHG emissions from 2023 onwards: 8 ktCO2e lower than the 

baseline per year. This represents a 0.7% increase compared to the baseline. 

See annex 4 for detailed calculations. 

Suboption: broad scope of the initiative  

The  impacts,  from  the  inclusion  of  tablets,  headphones,  headsets,  cameras,  portable 
speakers,  and  handheld  videogame  consoles,  are  the  impacts  exposed  in  option  1  and 
option 2. 

An extended scope to tablets, headphones, and cameras, change the different impacts to the 
following figures when comparing to the baseline (refer to Annex 4 for more details):  

  The  turnover  of  the  worldwide  industries  decreases  of  around  215  million  EUR 
yearly and 25 million  EUR  yearly for EU industries,  and decrease of 364 million 
EUR yearly for distributors and retailers. 

  The consumers will save approximately 790 million EUR yearly; 
  The  material  use  increases  by  55  tonnes  more  yearly,  the  e-waste  increases  by 

around 100 tonnes yearly and GHG emissions decreases by 1 ktCO2 yearly. 

As for option 1, and 2, handheld videogame consoles and portable speakers, for which data 
was not possible to gather, are assumed to provide a proportional similar impact depending 
on the number of units that are currently sold on the market (see Table 5). 

Stakeholders’ views on the policy option: Manufacturers do not support this option, nor 
the  suboption.  EU  MS  have  different  views,  with  an  overall  majority  in  favour.  The 
European Parliament and consumers’ associations would welcome this Option, even if the 
European Parliament may question the absence of unbundling. 

6.6.  Policy Option 5 – A common connector in addition to Option 3 

This  option  is  built  on  the  policy  option  3  and  adds  the  measure  to  mandate  solution 
common connector (policy option 1), i.e. it is a combination of the mandatory measures in 

47 

 
options  1  and  3,  to  which  we  refer  for  a  description  of  the  option.  Only  the  combined 
effects of these two options are described below.  

Some of the impacts of this package would be slightly greater or smaller than the sum of 
those  of  options/measures  individually,  due  to  the  synergy  effect,  notably  because  the 
elimination of USB micro-B in the different measures does not stack-up, and because the 
impacts are increased thanks to the synergy between harmonised communication protocols, 
informing consumer about charging and unbundling of EPS.  

Economic impacts: 

Impact on economic operators: Under this option, the impacts of policy option 1 and 3 will 
be combined. The manufacturers of mobile phones using a proprietary connector will need 
to ensure that charging via USB Type C is possible for all new products from the date of 
implementation of the changes in the Directive. This might entail some one-off adjustment 
costs. Other costs would concern the devices that are not already unbundled, as in option 3. 
The  most  affected  by  this  option  would  be  EPS manufacturers  that  currently  provide  the 
EPS to be sold in the box. For them, it will be a one-off cost to sell the charger separately 
and to arrange the related aspects (e.g. logistics, supply chain, etc). The EPS manufacturers 
would  need  to  steer  their  their  business  models  from  supplying  both  the  device 
manufacturer  and  the  general  public  to  supplying  to  a  greater  extent  the  general  public. 
Retailers and distributors will gain as discussed in option 3. It is therefore estimated that 
the combination the regulatory measures will lead to an overall decrease of turnover for the 
worldwide industry of 240 million EUR yearly (-14.20% compared to the base line), while 
it  is  expected  that  the  impact  on  EU  indsutry  will  be  an  increase  of  13  million  EUR 
yearly134 (+5.9% compared to the baseline). The consequences on distributors and retailers 
until the point of sale will generate for them an increase of turnover of 271 million EUR 
yearly (+8.5%). This is the result of 60 million EUR less of turnover each year from EPS 
sold  in  the  box,  combined  with  increase  of  standalones  sales  of  EPS  and  cables 
(respectively +3% and +8.1%). 

Impact on public authorities: Costs for public authorities would be the same as for options 
1 and 3 (i.e. negligible). 

Social impacts:  

Impact  on  consumers:  The  elimination  of  the  need  for  proprietary  connectors  and  cables 
will give a substantive economic gain to consumers, as discussed in option 1. Further gain 
will come from the savings and the information as in option 2. However, the measure of 
unbundling  will  decrease  the  benefits,  as  described  under  policy  option  3.  As  a 

134 see table 30 of https://data.europa.eu/doi/10.2873/788086 

48 

 
                                                           
consequence, this option will bring the overall gain for consumers to 3.2% compared to the 
baseline (210 million EUR yearly135 for the period 2024-2030). See annex 4 for details.  

Environmental impacts: 

The elimination of the EPS supplied in the box (60 million EPS less each year) surpasses 
the increase in the sales of standalone sales of EPS and cables due to the unbundling of the 
EPS, and the negative effect of heavier interface due from harmonisation. The net effect of 
this policy option, as regard to the environmental impact, is (see Annex 4 for details): 

  A decrease in the total materials required, with 14 944 tonnes fewer materials used 
compared  to  the  baseline  total  between  2024-2030,  or  around  2  135  tonnes  per 
year.  This  represents  a  9.8%  decrease  compared  to  the  baseline.  The  most 
substantial changes are observed in ‘plastics’, ‘alumnium‘ and ‘others (EPS)’. 
  A decrease in  the e-waste  generated, with  5 647  less tonnes of e-waste  generated 
than  the  baseline  total  between  2024-2030,  or  around  807  tonnes  per  year.  This 
represents a 4.2% decrease compared to the baseline. The same trend is observed in 
the amount of untreated and recycled e-waste. 

  A significant decrease in GHG emissions, with emissions 1 028 ktCO2e lower than 
the  baseline  total  between  2024-2030,  or  around  147  ktCO2e  per  year.  This 
represents an 13.1% decrease compared to the baseline.  

Suboption: broad scope of the initiative 

The  impacts,  from  the  inclusion  of  tablets,  headphones,  headsets,  cameras,  portable 
speakers,  and  handheld  videogame  consoles,  are  the  combination  of  the  impacts  from 
options 1 and 3. 

An extended scope to tablets, headphones, and cameras, change the different impacts to the 
following figures when comparing to the baseline (refer to Annex 4 for more details):  

  The turnover of worldwide industries decreases of 350 million  EUR  yearly  while 
this option is  expected to have a positive impact on EU industries turnover of 22 
million EUR yearly and a positive impact on distributors and retailers turnover of 
457 million EUR yearly; 

  The gain to consumers will be 246 million EUR yearly; 
  The  material  use  decreases  by  2  606  tonnes  less  yearly,  the  e-waste  decreases  by 

980 tonnes yearly and GHG emissions decreases by 184 ktCO2 yearly. 

As for option 1, and 3, handheld videogame consoles and portable speakers, for which data 
was not possible to gather, are assumed to provide a proportional similar impact depending 
on the number of units that are currently sold on the market (see Table 5). 

135 see table 30 of https://data.europa.eu/doi/10.2873/788086 

49 

 
                                                           
Stakeholders’ views on the policy option: Manufacturers do not support this option, nor 
the sub-option. EU MS have different views, with a majority in favour. As per option 3, the 
majority of consumers would prefer to receive a charger in the retail box of the phone. The 
European Parliament would welcome this Option. 

7.  HOW DO THE OPTIONS COMPARE? 

A synoptic of the yearly impacts are reported in the table 6 below. 

Table 6 - synoptic of the yearly impacts for the period 2024-2030 
Difference in 
turnover for 
economic 
operators136 

Consumers’ 
savings 

GHG 
emissions 

Required 
material 

e-
waste 

No 
change 
+1.5% 
+2.1% 
-0.8% 
-0.5% 
-8.7% 
-10.0% 
-0.6% 
+0.2% 
-9.8% 
-10.2% 

No 
change 
+0.8% 
+1.3% 
-0.3% 
-0.1% 
-3.8% 
-4.7% 
-0.1% 
+0.4% 
-4.2% 
-4.4% 

No 
change 
+1.6% 
+1.9% 
-0.9% 
-0.6% 
-12.1% 
-13.8% 
-0.7% 
-0.1% 
-13.1% 
-14.2% 

No change 

No change 

549 m€ 
620 m€ 
168 m€ 
166 m€ 
2 m€ 
-35 m€ 
720 m€ 
791 m€ 
211 m€ 
246 m€ 

-410 m€ 
-440 m€ 
-137 m€ 
-136 m€ 
166 m€ 
273 m€ 
-547 m€ 
-578 m€ 
30 m€ 
105 m€ 

Policy Option 

0 – baseline 

1 – narrow scope 
1 – broad scope 
2 – narrow scope 
2 – broad scope 
3 – narrow scope 
3 – broad scope 
4 – narrow scope 
4 – broad scope 
5 – narrow scope 
5 – broad scope 

Total 
consumers + 
economic 
operators 

139 m€ 
180 m€ 
31 m€ 
30 m€ 
168 m€ 
238 m€ 
173 m€ 
213 m€ 
241 m€ 
351 m€ 

Table 7 provides information comparing the policy options in terms the two objectives that 
triggered the initiative. 

Options 
Policy option 0 
Policy option 1 
Policy option 2 
Policy option 3 
Policy option 4 
Policy option 5 

Table 7 - policy objectives and policy options 
Environmental benefits 
No change 
+- 
+- 
++ 
+- 
++ 
Legend:  +-  almost  no  impact;  +  reduced  positive  impact;  ++  positive  impact;  ++  very  positive 
impact 

Consumer convenience 
No change 
+++ 
++ 
+- 
+++ 
++ 

Table 8 provides information comparing the policy options in terms of effectiveness (how 
each  option  achieves  the  specific  objectives)  and  efficiency  (cost-benefits  analysis)  and 
coherence  with  other  pieces  of  EU  law.  Administrative  costs  and  impacts  on  EU 

136 namely worldwide manufacturers, retailers, distributors 

50 

 
 
 
                                                           
manufacturers  and  Authorities  are  negligible  or  already  falling  under  the  BaU  under  all 
options and will not be reported anymore. 

Table 8 - comparison of policy options 

Effectiveness 

Efficiency 

Policy 
option 0 

In  terms  of  consumer  convenience  and  environmental 
impacts,  the  status  quo  described  in  section  2  will  be 
preserved. 

Coherence 
There  is  no  conflict  of 
coherence  with 
the 
existing EU legislation 

not 

drivers 

This option resolves one of 
the  major 
of 
problems  (the  absence  of  a 
common  connector)  but  it 
addresses 
does 
performance 
minimum 
concerning  fast  charging, 
information  to  consumers 
and 
a 
e-waste.  As 
consequence  not  all  drivers 
are addressed. It contributes 
indirectly 
to  safety  and 
counterfeit issues. 

on 

only 

This  policy  option  introduce 
costs 
those 
manufacturers  that  are  using 
interfaces. 
proprietary 
Consumers’  convenience  will 
be  improved,  but  not  to  the 
maximum. 

Compliance costs are expected 
to  be  one-off  and  applicable 
only  to  a  minor  part  of  the 
market.  In  any  case  they  can 
be 
an 
appropriate 
the 
applicability of the option. 

through 
in 

reduced 

delay 

Policy 
option 1 

Policy 
option 2 

Policy 
option 3 

of 

resolves 
option 
This 
another 
the 
of 
driver 
problems  (the  unjustified 
limitation 
the 
performance by the device), 
but  it  does  not  reduce  the 
the 
fragmentation 
connectors and  e-waste.  As 
a 
all 
consequence  not 
drivers  are  addressed.  It 
contributes 
to 
safety 
counterfeit 
issues. 

indirectly 

and 

on 

2, 

This  option  builds  on 
addressing 
option 
environmental 
matters 
through  unbundling  but 
the 
leaving 
the 
interoperability 
connectors. 

unresolved 
on 

Policy 
option 4 

This  option  combines  the 
impacts of policy options 1 

on 

only 

This  policy  option  introduce 
costs 
those 
manufacturers that are limiting 
the  charging  performance  of 
their 
devices.  Consumers’ 
convenience will be improved, 
but not to the maximum. 

In addition to impact of policy 
option  2,  this  policy  option 
introduce further costs only on 
those  manufacturers  that  are 
not 
towards 
unbundling of their products.  

moving 

Compliance costs are expected 
to be one-off. In any case they 
can  be  reduced  through  an 
appropriate 
the 
applicability of the option. 
This  policy  option  introduce 
costs  on  those  manufacturers 
that  are  using  proprietary 

delay 

in 

51 

Other  pieces  of  EU  law, 
see  Annex  6,  do  not 
cover  this  aspect,  hence 
these 
are 
options 
coherent  with 
the  EU 
acquis. 

Other  pieces  of  EU  law, 
see  Annex  6,  do  not 
cover  this  aspect,  hence 
this  option  is  coherent 
the  EU  acquis. 
with 
Information  to  users  is 
already a provision in the 
RED.  This  option  will 
complement it.  

This  measure  would  be 
coherent  with  the  policy 
of  the  Union  to  reduce 
waste  and  promote  a 
circular  economy.  It  will 
not  have  overlaps  with 
environmental 
the 
legislation  described  in 
section 1 and Annex 6. 

Other  pieces  of  EU  law, 
see  Annex  6,  do  not 

 
 
 
 
and  2, but  does  not  resolve 
environ-
nor  mitigates 
mental  matters 
through 
unbundling. 

Policy 
option 5 

4, 

This  option  builds  on 
option 
addressing 
matters, 
environmental 
hence  it  has  the  highest 
mitigation  of  the  identified 
problems. 

interfaces and that are limiting 
the  charging  performance  of 
their devices.  

Compliance costs are expected 
to be one-off. In any case they 
can  be  reduced  through  an 
appropriate 
the 
applicability of the option. 

delay 

in 

Consumers’  convenience  will 
be improved to the maximum. 
This  policy  option  introduce 
costs  on  those  manufacturers 
that  (i)  are  using  proprietary 
interfaces,  (ii)  are  limiting  the 
charging  performance  of  their 
devices  and 
(iii)  are  not 
moving towards unbundling of 
their products.  

Compliance costs are expected 
to be one-off. In any case they 
can  be  reduced  through  an 
the 
appropriate 
applicability of the option. 

delay 

in 

cover  this  aspect,  hence 
this  option  is  coherent 
with 
the  EU  acquis. 
Information  to  users  is 
already a provision in the 
RED.  This  option  will 
complement it. 

This  measure  would  be 
coherent  with  the  policy 
of  the  Union  to  reduce 
waste  and  promote  a 
circular  economy.  It  will 
not  have  overlaps  with 
environmental 
the 
legislation  described  in 
section 1 and Annex 6. 

Consumers’  convenience  will 
be  improved,  but  not  to  the 
maximum. 

The assessment of the impacts can be visualised as follow: 

Table 9 - Impacts of policy options 

Social impacts 

Environmental impacts 

Economic 
impacts 

Options/impacts 
relative to the 
baseline 
Policy option 0 
Policy option 1 
Policy option 2 
Policy option 3 
Policy option 4 
Policy option 5 
Legend:  +-  almost  no  impact;  +  reduced  positive  impact;  ++  positive  impact;  -  minor  negative 
impact; -- negative impact; --- significant negative impact 

no change 
+- 
+- 
++ 
+- 
++ 

no change 
+++ 
++ 
+- 
+++ 
++ 

no change 
-- 
- 
++ 
-- 
++ 

The overall support to the initiative can be visualised as in the following tables. 

Options 

Member States 

European 
Parliament 

Consumers 
Associations 

Equipment 
manufacturers 

Table 10 – Support to the Initiative 

52 

 
 
 
 
 
 
Policy option 0 
Policy option 1 
Policy option 2 
Policy option 3 
Policy option 4 
Policy option 5 
Legend: --- completely adverse;  -- not in favour; - not so in favour; +- neutral; + marginally in 
favour; ++ in favour; +++ significantly in favour – for a more detailed explanation, see Section 6 

--- 
+ 
- 
+- 
++ 
+++ 

+++ 
-- 
- 
-- 
--- 
--- 

--- 
++ 
+ 
+- 
+++ 
++ 

- 
+ 
+ 
+ 
+ 
+ 

Table 11 – Support to the Scope 

Options 

Member States 

Narrow 
Broad 

- 
+ 

European 
Parliament 
--- 
+++ 

Consumers 
Associations 
--- 
+++ 

Equipment 
manufacturers 
+++ 
-- 

Legend: --- completely adverse;  -- not in favour; - not so in favour; +- neutral; + marginally in 
favour; ++ in favour; +++ significantly in favour 

8.  PREFERRED OPTION 

8.1. 

Preferred policy option: option 5 with a broad scope 

Analysing the summary table 5 in section 7, it can be noted that  

  Options 1 and 4 mostly maintain the status quo as regards environmental matters, 
but  provide  the  most  benefits  to  consumers,  at  the  expense  of  the  economic 
operators; 

  Also option 2 mostly maintain the status quo as regards environmental matters, but 
provide  the  reduced  benefits  to  consumers,  which  are  also  de  facto  offset  by  the 
turnover of the economic operators; 

  The  policy  options  3  and  5,  mandating  unbundling,  maximise  the  environmental 
benefit but in the case of consumers’ convenience option 3 scores much worse than 
option  5.  In  fact,  option  3  maximises  the  gain  for  the  economic  operators,  at  the 
expense of the consumers. 

It  is  therefore  clear  that  there  is  no  solution  that  allows  to  reach  the  maximum  for  both 
intended  policy  objectives.  This  is  because  maximising  consumers’  convenience  (e.g. 
providing  a  charger  in  each  retail  box)  would  in  turn  maximise  e-waste  and,  vice  versa, 
minimising  e-waste  has  an  impact  on  consumers’  convenience.  In  this  multifunction 
maximisation,  option  5  allows  to  achieve  the  fairest  trade-off  between  all  the  needed 
achievements.  Under  this  option,  the  consumer  convenience  will  not  be  the  maximum 
possible,  but  it  will  be  increased.  At  the  same  time  this  option  –  on  aggregate  –  will 
maximise  the  benefits  for  consumers  and  economic  operators  and  the  environment.  The 
decrease of consumer convenience with respect to option 3 is due to unbundling, which has 
been  identified  in  the  surveys  a  source  of  inconvenience.  At  the  same  time,  however, 
unbundling makes it in turn possible to reach the highest environmental benefits from the 
initiative  and  to  mitigate  the  losses  for  the  economic  operators.  As  a  result,  it  allows  to 

53 

 
achieve a win-win situation for all the represented categories and the environment and it is 
therefore the preferred policy option. With respect to the scope, the analysis shows that the 
cost-benefit improves when more devices are in scope. 

With respect to the selected connector and technology, this will be USB Type C and for the 
fast charging communication protocol, it will be USB PD, as detailed in Annex 5.  

However,  there  may  be  certain  risk  with  the  mandatory  measures  of  this  option,  which 
would require mitigation.  

A  first  identified  risk  is  hindering  innovation  when  mandating  the  harmonisation  of  the 
end-device interface. Article 3(3) of the RED empowers already the Commission to adopt 
delegated  acts  to  specify  the  categories  or  classes  that  are  concerned  by  each  of  the 
essential requirements enumerated in paragraph 3, including that “radio equipment shall be 
so  constructed  so  that  they  interwork  with  accessories,  in  particular  with  common 
chargers” (subparagraph a). However, in the absence of an empowerment to define one or 
more “common chargers”, an amendment of the RED is needed to ensure legal certainty in 
the  selection  of  the  needed  interface.  The  changes  in  the  technical  specifications  will  be 
defined  by  the  progress  in  the  standardisation  exercise.  As  a  result  of  the  above 
considerations, the Commission will propose an amendment to the RED, where (i) specific 
clauses of the standard concerning the USB type C137 will be mandated, (ii) manufacturers 
will  be  obliged  to  place  at  least  unbundled  products  on  the  EU  market  and  (iii)  the 
information to the consumers will be improved (for all those aspects, see Sections 6.1 and 
6.2). This initiative will not include other legal basis then the RED, even if coherent and 
complementary actions will be taken under the legislation described in Annex 6. 

The possibility to update in a timely manner the specific clauses of the standard concerning 
the common solution is key to ensure that the technology is not outdated. For this purpose, 
the  Commission  will  propose  to  the  co-legislators  to  grant  an  empowerment  to  make 
updates through delegated acts. Industry has already joined forces to standardise interfaces 
(e.g. in USB-IF in 1995, where Apple is a founder) and this work will not be impeded as 
long as interoperable solutions are produced. Industry is therefore expected to keep up with 
the efforts of the past and produce interoperable, open and non-controversial solutions to 
be  adopted  through  delegated  acts.  This  will  minimise  the  risks  to  innovation,  whilst 
maintain the consumers’ and the environmental convenience. 

137 At the time of drafting this impact assessment it is noted that CENELEC released  

  EN IEC 62680-1-3:2021 ‘Universal serial bus interfaces for data and power - Part 1-3: Common 

components - USB Type-C Cable and Connector Specification’ and  

  EN IEC 62680-1-2:2021, ‘Universal serial bus interfaces for data and power - Part 1-2: Common 

components - USB Power Delivery specification’ 
which will be the basis for the provisions therein described 

54 

 
                                                           
Linked  to  innovation,  there  is  the  risk  to  include  in  scope  equipment  which  cannot 
accommodate the common interface for physical dimension. For this reason, earbuds will 
not be in scope. 

A  second  identified  risk  concerns  disproportionality  in  mandating  the  support  of  the 
relevant charging protocol on the end-device. As explained in section 6.3, devices will be 
requested  to  support  the  appropriate  USB  charging  protocols,  up  to  their  maximum 
charging power. This will allow the chargers and the devices to negotiate the power level 
to  what  is  achievable  by  both  and  hence  will  allow  the  best  (and  safe)  charging 
performance.  Devices  will not  be requested to  support power levels  above the maximum 
they can support, as this would not be proportionate. 

A third category of risks concern the compliance costs. In section 6, these are considered 
negligible  or  reasonably  negligible  in  the  absence  of  specific  data  and  under  the 
assumption of a transition period for the new provisions in line with the average lifetime of 
products. On the one hand, the USB type-C specifications, which are already described in 
an international and European standards, will be mandated. The legal draft will suggest a 
minor  amendment  to  the  conformity  assessment  procedures  concerning  the  essential 
requirement in Article 3(3)(a), so to allow the manufacturers’ self-assessment and avoid a 
mandatory  involvement  of  Notified  Bodies  in  the  conformity  assessment  procedures.  On 
the  other  hand,  there  is  the  risk  that  a  short  transition  period  would  require  certain 
manufacturers to redesign their products. However, the time needed for the co-legislation 
procedure,  together  with  an  appropriate  deadline  to  MS  to  transpose  the  new  provisions, 
will provide a sufficiently  long transition  period138 to  manufacturers to  plan and adapt  in 
advance to the new provisions, so that any related cost (e.g. to redesign the product or to 
provide  additional  information  on  the  package)  can  be  absorbed  under  the  Business  as 
Usual for new models. 

A fourth risk may concern consumers’ costs related to dismissing certain accessories. As 
regards those accessories, other than the considerations in section 6.2, it is noted that the 
transition period will further mitigate the inconvenience. 

A fifth  risk concerns the possible creation of a non-tariff barrier, with  specific respect  to 
the Agreement on Technical Barriers to Trade139. In that respect, Section 6 explains why 
this  is  presumed  not  to  create  an  unnecessary  obstacle  to  international  trade,  as  per  the 
Agreement itself.  

A  further  argument  can  be  the  proportionality  of  the  measure  to  mandate  unbundling, 
under the assumption that the market  appears to move in  that direction. In that regard, it 
has to be noted that specific manufacturers, as per their interviews during the stakeholders’ 
consultations, would decide not to unbundle, so to keep up with the consumers’ preference. 

138 as a function of the average lifetime of the equipment 
139 https://www.wto.org/english/docs_e/legal_e/17-tbt_e.htm  

55 

 
                                                           
There  are  therefore,  for  the  time  being,  only  specific  manufacturers  who  decided  to 
unbundle.  In  turn,  in  the  long  term  this  can  create  an  uneven  ground  for  manufacturers, 
some  of  which  may  decide  to  re-bundle  the  chargers  with  the  mobile  phones  aiming  to 
restore a level playing field. This would significantly affect the benefits of this initiative as 
regards the environment. In any case, it is acknowledged that the effects of this initiative 
will  be  tangible  after  the  date  of  applicability.  In  that  timeframe,  certain  consumers  may 
still  find  convenient  to  find  chargers  in  the  box  of  new  devices.  For  this  reason, 
manufacturers will be given the option to place on the market bundled solutions as long as 
unbundled  solutions  are  also  available.  This  will  mitigate  further  the  consumers’ 
inconvenience, should they not have a suitable charger at home. 

Finally,  this  initiative  will  be  adopted  through  co-decision  as  regard  to  a  revision  of  the 
Radio Equipment Directive 2014/53/EU. The date of applicability is currently assumed to 
be  a  couple  of  years  after  the  Commission  adoption.  As  regards  interwork  with  the 
complementary initiative on EPS, the “universal power supply” will take form of a revision 
of  the  EPS  Regulation  which  is  under  the  Eco-Design  and  does  not  require  lengthy  co-
decision  process.  The  proposal  is  expected  in  2022.  Given  these  different  legislative 
procedures, it is expected that both initiatives will enter into force in the similar period of 
time. 

8.2.  REFIT (simplification and improved efficiency) 

This  initiative  is  an  ad-hoc  revision  of  Directive  2014/53/EU  aiming  to  replace  the 
empowerment  in  Article  3(3)(a)  and  on  the  presentation  of  information.  Information  and 
instructions  are  already  foreseen  under  Article  10(8)  of  the  Directive  and  manufacturers 
address it each time they place radio equipment on the market. The obligation to add and 
present certain information in a more legible manner to consumers is not expected to create 
additional  administrative  burden  once  sufficient  time  in  line  with  the  average  lifetime  of 
models is provided to manufacturers to adapt. The other measures which comprise Option 
5  are  not  expected  to  create  additional  burden.  As  regard  simplification,  the  reduced 
proposed revision of the Directive is not expected to alter the current framework. 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

After  the  entry  into  force  of  the  revised  Directive,  the  Commission  will  monitor  the 
implementation,  the  application  and  the  compliance  to  the  new  provision  with  a  view  to 
assessing its effectiveness. The Commission is under the obligation to monitor and report 
the implementation of the Directive to the Council and the European Parliament. A report 
is due by 12 June 2023, as per Article 47 of the RED. However, the time for co-legislation 
and  the  delayed  transposition  date  will  allow  to  examine  implementation  aspects  only  in 
the  report  of  2028,  or  in  earlier  evaluations  of  the  Directive.  The  monitoring  framework 
would account for the information reported under the related pieces of EU law in Annex 6. 
This collective source of information will create an evidence base for a future evaluation of 
the functioning of the intervention.  

56 

 
  On the implementation, the Commission will spend significant efforts to ensure that 
the  common  interface  is  fit  for  the  purpose  and  will  monitor  technological 
advancements.  In accordance with Article 47(2) of the Directive, the Commission 
will  report  the  state-of-play  of  the  implementation  of  the  Directive,  including  the 
aspects herein discussed, to the Council and European Parliament by 2028; 

  On the application, by means of the reports of Member States in Article 47(1), the 
Commission  will  verify  that  no  conflicting  national  initiatives  would  have  been 
taken;  

  The general effectiveness will be monitored in conjunction with the other relevant 
pieces  of  EU  law,  and  the  Commission  will  monitor  the  reports  of  Market 
Surveillance  Authorities,  which  are  regularly  submitted  to  the  Expert  Group  on 
Radio Equipment.  

In more detail the above can be described as follows:  

Indicator 

Definition 

Reduction of 
e-waste 

As in the WEEE 

Table 13: monitoring strategy 

Unit of measurement 
Absolute volumes of 
sold and disposed 
chargers 

Baseline 

Previous 
volumes and 
related trend 

Harmonisation 
of the 
interface  

As in the 
relevant 
standard 

Percentage of compliant 
and non-compliant 
products 

Estimates of 
the previous 
years 

Harmonisation 
of the 
protocols for 
fast charging 

As in the 
relevant 
standard 

Percentage of compliant 
and non-compliant 
products 

Estimates of 
the previous 
years 

Presence of 
information to 
consumers 

As in the 
modified articles 

Percentage of compliant 
and non-compliant 
products 

N/A 

Unbundling 

As in the 
modified articles 

Percentage of compliant 
and non-compliant 
products 

Estimates of 
the previous 
years 

Safety 

As in Article 
3(1)(a) of the 
RED 

Percentage of compliant 
and non-compliant 
products 

Estimates of 
the previous 
years 

Data source 
Market and 
environmental 
statistics 
Annual 
reports/statistics of 
Market Surveillance 
Authorities 
Reports under Article 
47(1) of the RED 
Annual 
reports/statistics of 
Market Surveillance 
Authorities 
Reports under Article 
47(1) of the RED 
Annual 
reports/statistics of 
Market Surveillance 
Authorities 
Reports under Article 
47(1) of the RED 
Annual 
reports/statistics of 
Market Surveillance 
Authorities 
Reports under Article 
47(1) of the RED 
Annual 
reports/statistics of 
Market Surveillance 
Authorities and  
Consumers’ reports 

57 

 
58 

 
 
 
 
ANNEX 1: PROCEDURAL INFORMATION 

1.  LEAD DG, DeCIDE PLANNING/CWP REFERENCES 

The  lead  DG  is  the  DG  for  Internal  Market,  Industry,  Entrepreneurship  and  SMEs  (DG 
GROW).  The  Directorate  in  charge  was  Directorate  H  –  Ecosystems  III:  Construction  & 
machinery. The internal Planning entry was PLAN/2018/3079. 

2.  ORGANISATION AND TIMING 

An Inter- Service Group was set up with the participation of DG GROW, DG CNECT, DG 
COMP, DIGIT, EEAS, DG ENER, DG ENV, DG JUST, LS, DG RTD, SG, DG TRADE, 
JRC, DG SANTE.  

Meetings took place on 5 February 2021, 1 March 2021 and 5 May 2021. 

3.  CONSULTATION OF THE RSB 

This  impact  assessment was discussed at  a meeting with  the RSB on the 16th June 2021. 
The RSB issued its opinion on the 18th June 2021, following which this impact assessment 
has been revised as follows: 

Summary of findings 

RSB Recommendations 

The report  does  not  sufficiently  explain  the links  and 
coherence with other closely related policy initiatives, 
in particular the upcoming eco-design initiative on the 
universal  external  power  supply.  It  is  not  sufficiently 
clear  that  its  scope  does  not  include  regulating 
chargers. 

The rationale for some elements of this initiative is not 
sufficiently convincing. 

The  report  does  not  sufficiently  analyse  some  of  the 
impacts. It does not demonstrate the proportionality of 
the options, given their sometimes limited or negative 
impacts. 

The  options  do  not  specify  clearly  how  they  would 
improve  consumer  information.  They  also  remain 
vague  on  the  way  to  ensure  that  imposed  standards 
stay  in  line  with  technological  developments  and  do 
not prevent innovation. 

59 

Changes made in the IA Report 
Section  1  now  includes  a  more  specific 
complementing 
description  of 
the 
initiative 
eco-design 
framework. 

under 

the 

Sections  1  and  3  have  also  been 
modified  so  to  explain  in  a  better 
manner that this initiative concerns end-
devices, not chargers, for which the EPS 
legislation will apply. 

Sections  2,  6  and  8  have  been 
complemented 
additional 
explanations and rationales. 

with 

Section  8.1  has  been  deeply  revised 
enhancing  the  analysis  on  the  impacts 
and the proportionality 

Section  6  now  reports  more  granular 
details  on  innovation  (6.1),  consumers’ 
information (6.2). 

technological 
Timely 
developments are discussed in section 8. 

updates 

of 

 
What to improve 

(1) The report needs to clarify the relationship 
and coherence between this initiative and other 
upcoming  initiatives.  In  addition  to  the  eco-
design  initiative  on  the  universal  external 
power supply, this also concerns the upcoming 
eco-design  and  energy  labelling  initiative  on 
smartphone  and  tablets.  The  report  should 
explain  and  justify  the  scope  of  this  initiative 
in  relation  to  the  others.  For  this  initiative,  it 
should  particularly  clarify  that  it  does  not 
regulate chargers and that it does not introduce 
a common charger. 

report  should  present  a  more 
(2)  The 
convincing  and  coherent  rationale  for  the 
harmonisation  of  the  charging  connector  in 
devices  and  for  unbundling.  It  should  not  use 
consumer  preferences  as  the  main  argument 
for  the  harmonisation  of  the  connector  and 
ignore them when it comes to their preference 
for  bundling.  It  is  not  clear  why  the  report 
the  ongoing  market  evolutions 
considers 
towards  unbundling  insufficient.  The  report 
should 
that  consumer 
preferences  are  not  homogeneous,  which  is 
reflected  in  their  buying  behaviour.  It  should 
justify why it considers some of these revealed 
consumer  preferences  as  problematic. 
It 
should also provide evidence on the problems 
that 
related 
privilege 
over 
interoperability. 

to  current  business  models 

into  account 

proprietary 

solutions 

take 

improve 

they  would 

(3) The options should indicate more precisely 
how 
consumer 
information  on  interoperability  and  charging 
performance. The report needs to explain how 
new  information  requirements  will  be aligned 
with existing  and  potentially  new  information 
requirements  of  the  related  initiatives  (see 
above).  The  report  also  needs  to  discuss 
possible  options  on  transition  periods  and 
analyse their merits. 

(i) 

(ii) 

(iii) 

(iv) 

(i) 

(ii) 

(iii) 

(iv) 

(v) 

(i) 

(ii) 

(iii) 

(4)  The  report  should  better  explain  how  the 

(i) 

60 

on 

revised  with 
Section  1  has  been 
additional 
the 
information 
complementing initiative under the eco-
design framework; 
The  end  of  section  1.1  concerns 
specifically the initiative on smartphone 
and tablets; 
Sections  1  and  3.1  have  also  been 
modified  so  to  explain  in  a  better 
manner that this initiative concerns end-
devices, whilst other EU legislation will 
apply  to  EPS  as  these  devices  are  not 
radio equipment; 
In  section  3 
the  relevance  of 
the 
and 
the 
for 
initiative 
effectiveness  of  the  internal  market  has 
been strengthen. 

efficiency 

risks  not 

Section  8.1  has  been revised  explaining 
why option 5 allows to achieve the best 
cost-benefit analysis; 
The  same  section  also  explains  better 
the 
take  action  on 
to 
unbundling  with  respect  to  the  policy 
objectives of this initiative.  
It  also  explains  how  there  would  be  a 
measure 
into  account  non 
homogeneous  consumer  preferences  in 
light of the policy objectives;  
It finally explains how specific problems 
can be mitigated; 
Sections 
includes 
and 
considerations  on  problems  related  to 
current  business  models  that  privilege 
proprietary 
over 
interoperability; 

solutions 

take 

6.2 

to 

2 

and 

Sections 5 and 6.2 has been made more 
precise on the ways which would allow 
to  improve  consumer  information  on 
interoperability 
charging 
performance; 
8.1 
Section 
accordingly; 
The same section now also explains that 
the  transition  period  is  expected  to  be 
overall in line with the average lifetime 
of the equipment. 
Section  8.1  better  explains  how  the 

redrafted 

been 

has 

 
 
options  are  future  proof.  It  should  be  more 
specific on how the imposed standards will be 
kept up to date. It should be specific on what 
USB  power  delivery  standard  it  will  include, 
as  the  newest standard  supports  higher  power 
use than described in the report. 

(5)  The  report  should  analyse  the  impacts  on 
competition  and  innovation  in  more  detail.  It 
should  justify  why  it  considers  the  risk  for 
creating  non-tariff  barriers  to  be  limited.  The 
analysis of the social impacts needs to include 
the  cost  for  consumers  of  replacing  adapters 
(e.g.  to  HDMI  or  for  headphones)  when  the 
charging connector for their preferred brand is 
changed. 

(ii) 

(i) 

(ii) 

(iii) 

options are future proof and the imposed 
standards will be kept up to date; 
References  to  specific  recent  standards, 
which will serve as the basis for certain 
provisions,  have  been  included  in  the 
same section. 
Sections  6.2,  6.3  and  6.4  have  been 
revised 
including  considerations  on 
competition and innovation; 
The text before section 6.1 explains the 
extent to which the risk for creating non-
tariff barriers to are limited; 
the 
6.2 
Section 
considerations  on  social  costs.  The 
analysis 
is 
complemented by appropriate mitigating 
measures in section 8.1. 

presented 

includes 

therein 

also 

(6)  The  comparison  of  options  should  better 
analyse  the  proportionality  of  the  options.  It 
should  better justify  why  the  preferred  option 
contains  measures  with  limited  or  negative 
impacts. In particular, the harmonisation of the 
charging connector in the devices would have 
limited benefits for consumers, combined with 
negative 
environmental 
impacts. 

economic 

and 

(7) The key limitations and the potential risks 
of  the  methodology  used  should  not  only  be 
covered  in  the  methodological  annex  but 
should  also  be  taken  into  account  when  the 
results  of  the  analysis  are  presented  in  the 
main  report.  Sensitivity  analysis  should  be 
used to deal with key uncertainties, such as the 
proportion  of  consumers  who  choose 
to 
they  buy  an 
purchase  a  charger  when 
‘unbundled’ phone. 

4.  EVIDENCE, SOURCES AND QUALITY 

(ii) 

that 

to  explain 

(i)  A  new  column  has  been  added  to  the 
synoptic  table  in  section  7  to  better 
assess the benefits for the entire society 
(consumers  and  economic  operators)  in 
a quantitative manner; 
The  first  part  of  Section  8.1  has  also 
been  modified 
the 
preferred option has a holistic approach 
in  dealing  with  the  presented  problems 
where  a  common  maximum  cannot  be 
achieved. 
The  report  was  made  more  transparent 
on 
in 
the  methodology  explaining 
section 6 the main issues with obtaining 
quantitative data in certain cases; 
It was also explained that the analysis of 
each  suboption  would  be  more  precise 
on the key missing data; 
The  methodology  to  remedy  to  these 
issues was also explained. 

(i) 

(ii) 

(iii) 

Three  studies140  141  142  supporting  this  impact  assessment  have  been  carried  out  by 
consultants.  The  Commission’s  consultants  carried  out  a  number  of  interviews,  analysed 
the data from the public and the targeted consultations, complementing them through desk 
research and other case studies. The first study identified a positive cost-benefit analysis in 

140  https://op.europa.eu/en/web/eu-law-and-publications/publication-detail/-/publication/c6fadfea-4641-11ea-
b81b-01aa75ed71a1. 
141 https://data.europa.eu/doi/10.2873/788086 
142  https://data.europa.eu/doi/10.2873/537546  

61 

 
 
 
                                                           
the adoption of a common connector, but noted that unbundling would have magnified it. 
A second study, consequently, extended the analysis to unbundling and identified Option 5 
of  this  Impact  Assessment  as  the  best  trade-off  option  amongst  the  different  needs  and 
objectives  at  stake.  A  third  technical  study  concerned  the  state-of-play  of  the  wireless 
charging  to  understand  to  which  extent  (i)  fragmentation  is  ongoing,  (ii)  a  common 
solution is being sought by manufacturers and (iii) there are commonalities in the existing 
strands  of  work  which  may  eventually  converge  to  a  common  solution.  The  consultant’s 
research  was  based  on  data  including  from  Eurostat  (2019),  Statista  (2019),  Comtrade 
(2019), eMarketer (2017), Strategy analytics (2019), IDC Quarterly Mobile Phone Tracker, 
Q1 2019, RAPEX (2019) and own sample-based research. 

Complementary  information  was  taken  from  Study  on  the  Impact  of  the  MoU  on 
Harmonisation of Chargers for Mobile Telephones and to Assess Possible Future Options, 
RPA (2014) 

Evidence  was  also  gathered  in  the  Expert  Group  on  Radio  Equipment,  interview  with 
stakeholders and through public or targeted consultations.  

Whenever  quantitative  information  has  been  sought,  EU  sources  were  preferred  (e.g. 
reports or statements from ECB, EU Court of Auditors, Eurostat, EU Agencies, other EU 
Bodies,  etc).  Other  sources  were  also  considered  (e.g.  studies  or  reports  of  international 
organisations or firms, of associations of stakeholders, etc). The sources have been chosen, 
consequently, as reliable as possible. Similar data, when possible, were cross-checked. It is 
acknowledged  that  some  data  are  estimates.  In  order  to  compensate  for  possible 
inaccuracies, 
in  a 
conservative manner. 

this  document  benefits  were  repeatedly  estimated 

throughout 

The  stock  model  of  the  consultant  relies  on  a  number  of  assumptions,  but  the  most 
influential of these are the assumptions related to the number and type of chargers added to 
the model each  year. Sales of new phones are held constant across all options, as are the 
proportion of proprietary phones and by extension chargers.  

The  situation  is  more  complex  for  the  options,  when  variations  in  the  charger  types  are 
higher,  and  where  the  policy  typically  mandates  changes  that  are  more  beneficial  for 
interoperability and other impacts,  but  that  have  negative impacts on material  use and e-
waste.  This  impact  is  offset  by  the  effect  of  any  reduction  in  standalone  sales.  It  is 
important  to  note  that  whilst  the  assumptions  for  the  reductions  in  standalone  sales  are 
based  on  evidence  from  the  consumer  survey  or  a  logical  rationale,  these  are  only  best 
estimates of what may occur. 

The  stakeholder  consultation  consisted  of  (i)  online  public  consultation,  (ii)  targeted 
consultation and (iii) consumer panel. 

Details on the calculations and assumptions are given in Annex 4. 

62 

 
ANNEX 2: STAKEHOLDERS’ CONSULTATION 

1. 

INTRODUCTION 

In the context of the impact assessment on an initiative in support of harmonised charging 
solutions for mobile phones and other similar devices, various consultation activities were 
conducted between May 2019 and April 2021. The aim was to assess the potential areas of 
revision and the impacts of the suggested policy options on different targets. Here below is 
a summary table of all the consultations activities. 

Table 2.1 – Summary of consultation activities against type of stakeholder 

Consultation 
Activity 

Citizens 

Consu
mers 
Associa
tions 

Environ
mental 
Associa
tions 

Membe
r States 

Market 
Surveill
ance 
Auth. 

Non 
Gov. 
Organis
ations 

Manufa
cturers 
Associa
tions 

Manufa
cturers 

X 

X 

X 

X 

X 

Inception IA 
(2018-2019) 
Public Consultation 
2019 
Consumer Survey 
2019 
Consumer Survey 
2021 
Stakeholders 
Survey 2020-2021 
Targeted 
Interviews 2021 
Expert Groups 
Meetings 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

X 

2. 

INCEPTION IMPACT ASSESSMENT (2018-2019) 

In December 2018, the Commission published an inception impact assessment announcing 
its  plans  as  regard  to  the  common  charging  solution.  All  interested  stakeholders  could 
provide  feedback  on  the  inception  impact  assessment  for  a  six  week  period.  18  answers 
were provided143.  

3.  PUBLIC CONSULTATION (2019) 

A Public Consultation on chargers for mobile phones was launched by the European Commission 
on 14 May 2019 and closed on 6 August 2019. The Public Consultation achieved a total of 2,850 
respondents.  An  overwhelming  majority  were  EU  citizens  (2,743,  or  96%).  Non-EU  citizens 
accounted  for  34  entries,  resulting  in  a  total  of  2,777  responses  from  private  individuals  (97%). 
There were responses from citizens from all EU countries. Among the countries with the highest 
number  of  respondents  were  Italy  (13%),  followed  by  Romania  (12%),  and  Portugal  (8%).  The 

143 
mobile-phones-and-similar-devices 

https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/2020-Common-chargers-for-

63 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
majority of 34 companies, business organisations, and business associations144 that participated 
in the Public Consultation were mainly based in EU countries. 7 (21%) were from the UK, 5 (15%) 
from Germany, and 4 (12%) from Belgium. Responses were received also from companies based in 
Korea (1) and in the United States (3). Of the companies, 42% were from sectors that clearly have a 
direct stake in the initiative, whilst 13% were telecommunications companies, two testing bodies, 
and one a certification body. 19 individuals representing public authorities submitted their views. 
Fewer responses were received from NGOs, consumer organisations, and academic institutions 
– overall reaching 14 contributions. The three consumer organisations were from Belgium, Iceland, 
and  Italy,  whilst  two  NGOs  were  from  Belgium,  one  from  Bulgaria,  and  one  from  Switzerland. 
Among  the  NGOs  that  took  part  in  the  Public  Consultation,  only  one  had  a  clear  environmental 
focus.  

A clear majority of EU citizens indicated that the present situation was a source of inconvenience. 
Respectively, 42% and 34% respectively agreed or strongly agreed with this statement. Only 10% 
disagreed and 5% strongly disagreed with the statement. 8% held neutral views.  

EU citizens’ views are aligned with those expressed by NGOs and consumer organisations. Public 
authorities  had  more  nuanced  views,  although  generally  aligned  with  consumers  in  indicating 
financial  costs  and  environmental  reasons  as  the  two  single-largest  problems.  Businesses’  and 
business organisations’ opinions sometimes showed notable differences from consumers’ views in 
terms  of  environmental  impact  (30%  held  that  there  was  no  environmental  impact)  and 
inconvenience  (47%  indicating  that  no  inconvenience  was  caused  by  having  multiple  types  of 
chargers). In addition to this, variety was seen by 56% of businesses and business organisations as 
a positive factor.  

Inconvenience: Among those who indicated that the situation resulted in inconvenience (76%), the 
following were the main sources of inconvenience reported by respondents:  

  73% of EU citizens believed that users of different electronic devices need to have multiple 
chargers  which  occupy  space  and  may  lead  to  confusion  to  be  a  serious  problem,  while 
26% of respondents described this as a minor problem. Only 1% of did not consider it a 
problem.  

  EU citizens also indicated that it can be difficult to find a suitable charger when away from 

home, with 64% considering this a serious problem and 35% a minor issue.  

  Having  multiple  chargers  taking  up  space  or  generating  confusion  in  the  household  was 
considered a serious problem by 58% of respondents, while 39% considered this a minor 
problem. This was not deemed an issue by only 2% of respondents.  

Figure 2.1 – Current situation with charger for mobile phones 

144  Companies,  business  organisations  and  business  associations  are  often  referred  to  as  ‘businesses  and 
business organisations’, ‘the business sector’ or ‘the business sector’ throughout the report. ‘The industry’ are 
instead those directly involved in the production or trading of mobile phones or chargers.  

64 

 
                                                           
The views of those businesses and business organisation that reported inconvenience were aligned 
with those of consumers, although not having a suitable charger when travelling was indicated as a 
serious problem only by 54% of the business stakeholders in the subsample.  

Performance:  Longer  charging  time  for  a  fast-charging  enabled  phone  charged  with  a  different 
charger were a serious problem for 57% of EU citizens, a minor problem for 37%, and for 3% it 
was not a problem. Although performance issues are perceived as a problem also by the business 
sector,  less  than  half  of  businesses  and  business  organisations  consider  that  having  multiple 
chargers has serious consequences.  

Financial costs: When restricting the sample to consider the views of those reporting that having 
multiple types of chargers generates financial costs (N=1476, or 52%), the following results were 
found:  

  Needing  to  buy  a  replacement  charger  when  one  breaks  rather  than  re-using  one  was  a 
serious problem for 75% of the EU citizens in the subsample, and for 22% it was a minor 
issue. For 3% it was not a problem.  

  39% of the  EU  citizens  indicated  as  a  serious  problem  the  fact  that  new  phones  are sold 
with a new charger, resulting in a price increase. However, 45% considered that this was a 
minor problem, while for 15% this did not present any problems.  

Business  stakeholders  were  divided  on  whether  the  current  situation  increases  the  costs  for 
consumers.  

Safety:  A  clear  majority  of  EU  citizens  who  judged  that  the  situation  posed  a  safety  hazard 
(N=899,  or  32%),  indicated  that  unbranded  chargers  (80%)  or  chargers  not  specifically  designed 
for  the  mobile  phone  in  use  (72%)  may  be  potentially  unsafe.  Similar  views  were  expressed  by 
public  authorities,  concerned  with  limitations  to  interoperability.  However,  business  stakeholders 
appeared  more  likely  to  indicate  the  presence  of  counterfeit  chargers  as  a  serious  problem 
compared to EU citizens (90% vs 80%).  

Environment: EU citizens are concerned that old chargers may not be properly recycled or reused 
(91%),  while  8%  only  considered  this  a  minor  issue.  The  amount  of  e-waste  generated  by  old 
chargers was a serious concern for 93% of respondents and a minor problem for 6%. The depleting 
of  natural  resources  and  increasing  gas  emissions  linked  to  the  production  of  chargers  is 
highlighted as a serious problem by 86% of respondents, whilst it is considered a minor issue by 
12% of respondents. When considering businesses’ opinions, percentages are generally lower. 56% 
considered accumulating chargers at home or not recycling them as a serious issue (33% as a minor 
issue). 67% was seriously concerned by the consumption of scarce resources and CO2 emissions 

65 

 
 
resulting  from  the  manufacturing  process  (28%  indicated  this  as  a  minor  problem).  e-waste  was 
instead a serious concern for 67% of businesses and business organisations, and a minor problem 
for 28% of them.  

Should  the  EU  take  further  action  for  mobile  phones  chargers?  There  seems  to  be  strong 
consensus among EU citizens on the need for a universal charger model. A 63% majority was in 
favour  of  the  EU  exercising  its  regulatory  power  to  mandate  a  charger  standard,  whilst  31% 
considered that the EU should promote an industry-wide agreement. Support was also expressed by 
public  authorities,  non-governmental  organisations,  and  consumer  organisations  in  similar 
proportions.  Among  the  industry  sector,  35%  deemed  regulatory  action  necessary,  while  29% 
would opt for an industry-led agreement. Yet, 32% opposed further action.  

Other  devices  that  could  be  standardised:  88%  of  EU  citizens  indicate  a  preference  that  tablets 
could also be standardised. A high share of European citizens also supports the standardisation of 
chargers  for  cameras  (73%),  laptops  (74%),  e-readers  (76%),  and  smartwatches  (70%).  Public 
authorities  hold  stronger  views  compared  to  consumers  on  the  need  for  standardisation  of  other 
devices. For businesses only tablets seem to aggregate broad consensus (68%), with all other items 
being below 50% of support.  

4.  CONSUMER SURVEY (2019) 

A Consumer Survey (CS) was carried out in June 2019. A total of 5,002 respondents distributed 
equally among 10 countries participated in the survey. In order to achieve a representative sample 
across the 10 EU MS covered, responses were weighted by participating countries’ age and gender 
distribution, in addition to total population size of individual countries.  

Number of phone chargers owned: On average, respondents reported that they own three chargers.  

Chargers supplied with mobile phones: 80% of respondents indicated that the charger they use had 
been  provided  with  their  mobile  phone,  whilst  32%  reported  that  they  were  using  a  secondary 
charger  and  25%  as  an  additional  charger.  Chargers  provided  with  an  older  mobile  phone  were 
used  as  main  charger  by  7%  of  respondents,  whilst  27%  indicated  that  they  were  using  them  as 
secondary  chargers,  and  20%  as  a  third,  additional  charger.  Chargers  of  other  electronic  devices 
were  used  as  main  mobile  phone  chargers  by  only  4%  of  respondents,  whilst  12%  used them  as 
secondary chargers, and 17% as additional chargers.  

Types  of  connectors  on  the  device  (phone)  end:  100%  of  respondents  with  an  iPhone  indicated 
that their chargers were based on Lighting technology (only 3.4% among non-iPhone users). USB 
micro B is the most common connector type (95%) among respondents that do not own an iPhone, 
followed by USB Type C connectivity (51%).  

Preferences  for  a  standard  charging  solution:  The  standardisation  of  fast-charging  solutions 
found broad consensus among EU citizens (80% would support). Neutral views were expressed by 
14% of EU citizens, while 3% would be dissatisfied.  

Charging time: 51% of the sample indicated a charging time of less than 90 minutes, whilst 59% 
reported charging times were between 90 minutes and 2 hours. 30% of respondents cited that their 
phone  took  between  2  and  3  hours  to  complete  a  charge  cycle,  whereas  only  13%  more  than  3 
hours.  

Interoperability  of  chargers:  Most  respondents  (63%)  indicated  that  they  only  charged  their 
primary mobile phone with their primary charger. However, people aged 65 and over were more 
likely to use only their primary charger with their mobile phone (71%) compared to those aged 18 
to 25-years old (59%). 15% of respondents indicated that they used their mobile phone chargers to 

66 

 
charge  other  mobile  phones.  A  minority  of  respondents  (14%)  used  their  mobile  phone  chargers 
with other electronic devices. 

Cable and EPS interoperability: Most respondents who used their phone chargers for other mobile 
phones and/or other devices used both the cable and the EPS (58% for mobile phones and 53% for 
other  devices).  Differences  are  clear  between  iPhone and  non-iPhone  users;  while  approximately 
48% of iPhone users indicated that they used both the cable and EPS for other mobile phones, 60% 
of non-iPhone users did this. 16% did not use their mobile phone charger (cable and EPS) to charge 
other  chargers,  but  only  for  other  electronic  devices  (15%  among  non-iPhone  users,  22%  among 
iPhone users). When considering interoperability with other electronic devices. iPhone users were 
more likely to use only the EPS to charge other devices compared to non-iPhone users (28% and 
15% respectively).  

Charging  speed  with  other  mobile  phones:  26%  reported  performance  issues  when  using  their 
primary charger to charge other mobile phones. iPhone users were more likely (32%) to indicate 
absence of problems if they used another Apple charger, compared to others (19%).  

Reasons for purchasing a new charger: A broken charger cable was the main reason for buying a 
charger  (36%  of  cases).  The  second  most  cited  cause  was  the  convenience  of  having  a  spare 
charger  (28%).  Travelling  with  an  extra  charger  was  the  third  most  important  reason  (15%), 
followed by losing the original charger (14%), damage to the EPS (10%), wanting a faster charger 
(8%) or a wanting wireless charger (3%). 6% mentioned other reasons. Only 3% reported that their 
phone did not come with a charger as a reason.  

Characteristics of the new charger purchased: 31% bought an unbranded charger, whereas 25% 
purchased one from an unknown brand. A charger of a known brand, but not matching that of their 
mobile phone, was the choice of 21% of respondents. 13% of respondents were unable to provide 
information on the brand of their chargers. 11% bought a charger that was the same brand as the 
mobile phone. When buying a new charger, 47% did not buy a fast charging-enabled charger or a 
wireless charger. 39% opted for a fast-charging model, 8% were wireless and only 6% were both 
fast-charging  and  wireless.  The  factors  underpinning  the  choice  of  charger  where  compatibility 
with the mobile phone in use (56%), price (41%), speed of charge (18%) and safety (18).  

Disposal of used chargers: Accumulating chargers at home was the single most common way of 
dealing with old chargers (49% of cases). 23% of respondents declared that they disposed of old 
chargers by using recycling facilities, whilst 7% considered them generic waste. 17% re-used old 
chargers, and 14% passed them on to family or friends. Selling used chargers online was common 
only among 5% of respondents.  

Willingness  to  buy  a  phone  without  an  EPS:  Respondents  were  also  asked  whether  they  would 
consider buying a phone with only a cable, and without an EPS. 36% would not support this option, 
18% had no opinion, and 46% would be willing to buy a phone with only a cable included in the 
box. 12% would accept this without any price reduction. 8% would expect a price reduction of 5 
Euros in order to buy a phone without an EPS but only with a charging cable included in the box; 
11%  expected  a  10-Euro  reduction,  and  15%  a  15-Euro  discount.  When  considering  those  that 
would be willing to purchase a mobile phone with only a charging cable included, 52.9% would do 
so to save resources and reduce e-waste, 46% for reasons of convenience, as they already had too 
many EPSs, and 37% to save money.  

Frequency of problems with chargers: Overall, 84% of respondents had experienced at least one 
of  the  following  problems  at  least  once  or  twice  in  the  24-month  period  prior  to  the  survey.  As 
regards the different types of problems, the results are given in the figure below. 

67 

 
Figure 2.2 – Share of respondents experiencing problems 

Costs:  Within  the  same  24-month  reference  period,  only  15%  of  respondents  who  experienced 
problems  reported  incurring  any  financial  costs as  a result of a  problem  with  their  chargers. The 
share of respondents that had to bear costs as a result of problems with their chargers was higher 
among those aged 18 to 24 (27%) than among the older groups of the population (for those aged 
65+, only 6% reported financial costs). 

5.  CONSUMER SURVEY (2021) 

The consumer survey (CS) was carried out by Ipsos in January 2021 and collected responses from a 
representative sample of 5,010 respondents split evenly across the six largest EU Member States: 
France, Germany, Italy, Poland, Romania, Spain. The survey collected information about the type 
of  mobile  phones  and  chargers  in  use, as  well as their  experiences  with and  preferences  towards 
unbundling.  It  also 
information  about 
investigated  consumers’  awareness  by  providing 
environmental impacts, interoperability, charging speed, and counterfeit and explored the effect of 
this type of information on consumer preferences. 

How  frequently  do  consumers  use  different  types  of  chargers  to  charge  their  mobile 
phones? The Figure below illustrates the types of EPS used by the respondents. A similar 
question was asked about the cable of the charger, and responses were broadly similar. A 
majority of respondents (64%) reported to use the cable provided with their mobile phones 
to charge their phones, and one quarter used it most of the time. 

Figure 2.3 – Use of different type of chargers - Source: Ipsos (2021) 

0%

Percentage of respondents
20%

40%

60%

80%

100%

The original EPS that came with the mobile phone

62%

25%

7%

4%

An EPS you bought separately

8%

11%

22%

An EPS that came with another mobile phone

7%

12%

Another device (e.g. a laptop or power bank)

5%

8%

33%

40%

56%

45%

45%

An EPS that came with another electronic device

4%

8%

25%

Always

A wireless charger
Most of the time

5%

12%

4%
Occasionally

59%

75%
Don’t know

Never

3%

2%

3%

4%

4%

68 

 
 
 
How important is it to find a charger in the box?: Consumers appear to believe that it is 
important to have a charger in the box when purchasing a new mobile phone (see Figure 
2.4 below, N=5,010).  

Figure 2.4 – Importance to find the charger in the box - Source: Ipsos (2021) 

0%

10%

20%

30%

Percentage of respondents
50%

60%

40%

70%

80%

90%

100%

EPS
Cable

61%

72%

Very important

Quite important

Not very important

21%

11%

5%

2%

17%
Not important at all

7%
3%
Don’t know

The survey also sought to understand why respondents considered important (or not) that 
charging accessories were provided in the sale box. Among the respondents who were of 
the opinion that finding an EPS in the box with a new phone was not very important or not 
important at all, over half (56%) indicated considerations around convenience (e.g. having 
enough EPS at  home). 35% of respondents  preferred not  to  pay for the EPS, whilst  33% 
mentioned environmental concerns. 14% indicated that they would prefer continuing using 
the EPS they have, and 11% did not feel the need of a new EPS. A very similar question 
was also asked about the cable assembly. The figure below reports their responses. 

Figure 2.5 – Why is it important to find a charger 

0%

10%

Percentage of respondents
30%

40%

20%

Habit - I am used to finding a complete product in…

Safety - This guarantees my phone is charged safely
Performance - This guarantees my phone is charged…
Convenience - This way I do not have to think about…

Cost - This saves having to buy one separately
Other
Don’t know

1%

15%

37%

30%

Source: Ipsos (2021), consumer survey. N=4,469. 

50%

60%

54%

45%
44%

Does  the  provision  of  information  affect  consumer  preferences?  Respondents  were  then 
provided  with  information  on  four  different  aspects  related  to  chargers,  namely:  (i) 
Environment  (raw  materials,  CO2  emissions,  and  electronic  waste),  (ii)  Interoperability, 
(iii) speed of charge, and (iv) counterfeit. The two Figures below show that information on 
the negative environmental consequences and interoperability of chargers results in a fall 
of the share of those who find important having EPS and cable in the box.  

69 

 
 
 
 
 
Figure 2.6 – Importance to find a charger in the box after having received information about 

Environment impacts 

Interoperability aspects 

Percentage of respondents
50%

0%

100%

0%

Percentage of respondents
50%

100%

EPS

Cable

44%

50%

27%

16%

8%

28%

12%

6%

EPS

Cable

45%

52%

27%

17%

8%

26%

14%

6%

Very important

Quite important

Very important

Quite important

Not very important Not important at all

Not very important Not important at all

Don’t know

Don’t know

(2021), 
Ipsos 
Source: 
consumer survey. N=5,010. 
Consumer  reaction  to  information  about  charging  speed  and  the  presence  of  counterfeit 
chargers  does  not  appear  to  cause  marked  shifts  in  preferences  compared  to  when  the 
question  was  asked  before  any  complementary  information  was  provided.  Results  are 
shown the Figure 2.7. 

Source: 
consumer survey. N=5,010. 

(2021), 

Ipsos 

Figure 2.7 – Importance to find a charger in the box after having received information about 
Information on Counterfeit chargers 

Information about Speed 

Percentage of respondents
20% 40% 60% 80% 100%

0%

0%

Percentage of respondents
20%

40%

60%

80% 100%

EPS

Cable

52%

57%

26%

13%

6%

25%

11%

4%

EPS
Cable

63%

68%

21%

20%

8%

5%
4%

7%

Very important
Not very important
Don’t know

Quite important
Not important at all

Very important
Not very important
Don’t know

Quite important
Not important at all

Source: 
(2021), 
Ipsos 
consumer survey. N=5,010. 

Source:  Ipsos  (2021), 
consumer 
survey. 
N=5,010. 
After  providing  relevant  information,  78%  of  respondents  stated  that  the  inclusion  of  an 
EPS was (very or quite) important for them. This is only 4% lower than before providing 
information,  although  it  should  be  noted  that  the  proportion  of  those  for  whom  the 
inclusion of an EPS was very important fell more (by 9%). The proportion of respondents 
who  considered  the  inclusion  of  a  cable  (very  or  quite)  important  fell  by  8%  (to  81%), 
including a 16% drop of those who responded very important. This is shown in the figure 
below. 

What  choices  would  consumers  make  if  phones  were  sold  unbundled  from  their 
chargers?  The survey also  tested consumers’ reactions  to  two potential scenarios, one in 
which only the EPS is removed from the bundle, and one where devices are sold without 
both EPS and cable. One half of the respondents were presented with the former scenario, 
and the other half with the latter. 

Figure 2.8 - Importance of finding a charger in the box after information had been provided 

70 

 
 
 
 
 
0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

EPS
Cable

52%

56%

26%

25%

11%

7%

9%

6%

4%
4%

Very important

Quite important

Not very important

Not important al all

Don't know

Source: Ipsos (2021), consumer survey. N=5,010. 

Despite  previous  indications,  43%  of  consumers  would  re-use  their  EPS.  Around  a  third 
(31%)  would  opt  for  the  fast  (and  more  expensive)  EPS.  The  regular  EPS  would  be 
preferred by 15% of consumers. A cheaper charger or one from  a different  manufacturer 
would be chosen by 6% of respondents each. 

Stand-alone  charger  purchases:  All  respondents  were  asked  how  many  standalone 
chargers  (EPS  and/or  cables,  not  in  the  retail  box  of  a  phone)  they  had  bought  in  the 
previous 24 months. Results are as below.  

Figure 2.9 - Charging accessories bought separately in the past 24 months 

None

One

Two

Three or more

0%

EPS on its own (without a cable)

EPS and cable together (in the same box…

Cable on its own (without an EPS)

Source: Ipsos (2021), consumer survey. N=5,010. 

Percentage of respondents

40%

60%

20%

80%

100%

79%

69%
68%

16%

24%

4%
5%

20%

8%

Do consumers re-use or dispose of old chargers? The survey also explored consumers’ 
behaviours when it comes to having multiple (old) chargers at home. Responses do not 
vary considerably between EPS and cable. When responders have spare chargers, they tend 
to keep them in storage (39% for EPS, 35% for cables). Some have started re-using old 
charging accessories, especially cables (18%), but also EPS (15%). Respondents also gave 
their old chargers to relatives or friends for free (13% for the EPS, 14% for the cable). 
When disposing of them, 11% correctly recycled both EPS and cable and 4% sent them to 
an online recycler (both cable and EPS), whilst a slightly smaller share threw them in the 
general waste bin (6% for the EPS, 7% for the cable component). Selling old chargers was 
not overly common (5% sold their EPS, 6% their cables). However, around 40% did not do 
any of these. 

6.  STAKEHOLDER CONSULTATION (2020-2021) 

The following section presents the findings from the stakeholder survey conducted via EU 
Survey to explore stakeholders’ views on the common charging and unbundling initiatives. 
A  total  121  stakeholders  responded  the  survey  from  the  9  December  2020  until  the  25 
January of 2021. Out of all stakeholders who contributed to the survey, 84% of these were 
based in the EU, with the remainder based in Asia (8%), North America (4%) or elsewhere 
in  Europe  (4%).  Respondents  included  private  citizens  (31%),  private  companies  (23%), 
public  authorities  (23%),  and  civil  society  organisations  (18%).  The  private  company 
respondents were approximately split evenly between representatives of manufacturers of 

71 

 
 
 
 
 
mobile  phones  and  similar  devices  on  the  one  hand,  and  representatives  of  other  sectors 
(including manufacturers of other products, retailers and wholesalers) on the other. 

Stakeholders’  views  on  the  Common  Charging  Initiative:  Survey  results  reveal 
stakeholders’  support  towards  the  implementation  of  a  common  charging  solution 
legislation for mobile phones, as below 

Figure 2.10 - Stakeholders' views on the Common Charger Initiative 

Percentage of respondents

All cable assemblies that are used for charging mobile
phones should have the same connector (USB Type-C)…

The EU should adopt legislation to ensure all cable
assemblies have the same connector at the device end.

All external power supplies (EPS) for mobile phones
should be interoperable with all mobile phones, based…

The EU should adopt legislation to ensure all EPS for
mobile phones are interoperable with all mobile phones.

Strongly Agree
Tend to disagree

Tend to agree
Strongly disagree

57%

54%

67%

59%

17%

3%

7%

15%

17%

3%

5%

20%

18%

6%

4%

4%

16%

7%

4%

14%

Neither agree nor disagree
Don’t know

Source: Ipsos (2021), stakeholder survey. N=121, all respondents 
Stakeholders’  attitudes  towards  unbundling:  The  survey  responses  reveal  stakeholders’ 
support towards decoupling initiatives, as below. 

Figure 2.11 - Stakeholders' views on mobile phone unbundling 

Percentage of respondents

0%

20%

40%

60%

80%

100%

All mobile phones should be sold with a complete
charging solution (EPS and cable) in the box.
All mobile phones should be sold with a cable, but
no EPS in the box. If needed, the EPS can be…
All mobile phone manufacturers / distributors
should give customers the option of purchasing…

All mobile phones should be sold with neither an
EPS nor a cable in the box. If needed, these can…
Each mobile phone manufacturer / distributor
should be free to choose how they sell their…
Strongly Agree
Tend to disagree

Tend to agree
Strongly disagree

16%

9%

11%

21%

8%

19%

10%

24%

42%

36%

41%

28%

10%

10%

8%

26%

13%

14%

21%

22%

25%

14%

8%

14%

37%

Neither agree nor disagree
Don’t know

Source: Ipsos (2021), stakeholder survey. N=121, all respondents 

Perceived benefits and risks of unbundling: Respondents anticipated different benefits and 
risks  from  the  widespread  unbundling  of  chargers  from  phones  in  the  EU.  The  most 
common are in the next figure. 

Anticipated  market  reactions  to  unbundling:  Finally,  private  companies  were  asked  to 
provide  their  views  on  the  likelihood  of  different  market  reactions  to  making  the 
unbundling  of  EPS  from  phones  mandatory.  Over  half  of  respondents  stated  that,  if 
unbundling is made mandatory in the EU it is unlikely that (i) manufacturers will offer a 
greater  variety  of  EPS  for  purchase  than  would  have  been  the  case  without  unbundling 
(65% of respondents thought it is quite/very unlikely), (ii) the retail price of mobile phones 
will be reduced (64% of respondents thought it is quite/very unlikely for this to happen in 
the short term; 57% of respondents thought it is quite/very unlikely to happen in the long 
term)  or  that  that  EPS  are  offered  at  a  discount  to  customers  purchasing  a  new  mobile 

72 

 
 
 
 
phone  (54%  of  respondents  thought  it  is  quite/very  unlikely);  (iii)  most  mobile  phone 
manufacturers  or  distributors  will  have  to  make  significant  changes  to  their  business 
models and/or processes (53% of respondents thought it is quite/very unlikely that phone 
distributors  will  change  their  business  models;  50%  thought  it  is  quite/very  unlikely  that 
this applies to phone manufacturers). 

Figure 2.12 - Anticipated changes of widespread unbundling of chargers from mobile phones 

0%

20%

Percentage of respondents

40%

60%

80%

100%

Total  number of new mobile phone chargers sold

Greenhouse gas emissions

11%
3%

9%

18%

12%

19%

15%

32%

5%

38%

23%

14%

Consumer convenience

31%

8%

17%

Prices for consumers

13%

Profits of mobile phone manufacturers

8%

17%

26%

24%

Profits of legitimate charger manufacturers

17%

26%

23%

31%

17%

5%

4%

12%

Profits of counterfeit charger manufacturers

Product safety risks for mobile phones and/or…

Conformity assessment, inspection and/or…

26%

26%

27%

Innovation in charging technology

Competitiveness of EU businesses

15%

14%

Competitiveness of EU SMEs

12%

36%

17%

9%

2%

18%

14%

10%

16%

14%

6%

11%

17%

37%

6%

3%

6%

26%

21%

31%

26%

5%

2%

9%

29%

24%

7%

17%

8%

18%

20%

30%

31%

12%

5%

21%

9%

6%

22%

Major increase Minor increase No change Minor decrease Major decrease Don’t know

Source: Ipsos (2021), stakeholder survey. N=121, all respondents 

7.  TARGETED INTERVIEWS 

Targeted interviews were also conducted in 2021, they concerned: one Market Surveillance 
Authority,  one  European  Standardisation  Organisation,  one  international  organisation,  7 
manufacturers associations, 17 manufacturers, 2 consumers’ associations, 4 environmental 
and recycling organisations. 

The wireless study was a technical study and interviews were limited to technical aspects. 
10 manufactures were interviewed on technical aspects. 

8.  EXPERT GROUP MEETING CONSULTATION (2020-2021) 

Consultations  of  the  stakeholders  in  the  Expert  Group  on  Radio  Equipment  took  place  in  the 
meetings of 2 March 2020, 25-26 February 2021 and 28 April 2021.  

 
In favour of option 5: Cyprus, France, Germany, The Netherlands, Slovakia, and Spain. 
  Not in favour of option 5: Denmark, Greece, Italy, and Sweden arguing that intervention 
on the matter at hand would hamper innovation and that unbundling is already happening. 

73 

 
 
 
 
ANNEX 3: WHO IS AFFECTED AND HOW? 

1.  PRACTICAL IMPLICATIONS OF THE INITIATIVE 

The  initiative  will  concern  a  significant  share  of  EU  population145,  manufacturers  of 
smartphones and other electronic devices. 

Consumers: the initiative will directly affect approximately 20% of users who, without this 
initiative,  would  continue  using  mobile  phones  with  a  proprietary  or  legacy  types  of 
connectors.  In  the  short  term,  they  may  suffer  inconvenience.  However,  considering  the 
average lifetime of the devices in scope and the sufficient time that will be provided to the 
manufacturers to adapt, the  

Manufacturers  of  mobile  phones:  The  preferred  option  would  entail  adaptation  costs  and 
foregone revenues for a major manufacturer that currently use proprietary connectors. The 
main impact is associated with necessity to adapt production lines to include USB type C 
connector for those manufacturers who have so far preferred proprietary solutions. Using a 
common  connector  will  allow  to  establish  a  level-playing  field  also  across  the  supply 
chain.  

Public authorities: The impact  would be associated with  surveillance  and enforcement of 
additional requirements. Given that control and surveillance systems are already in place, 
the marginal cost is expected to be negligible.  

SMEs: No major impacts are to be expected on SMEs as the mobile phone manufacturers 
are  large  companies.  There  could  be  however,  adaptation  costs  in  the  supply  chain  of 
manufacturers currently using the proprietary solutions such as for designers of tailor-made 
charging  solutions  and  distributors.  In  interviews,  these  companies  clarified  that  the 
initiative  would  only  affect  them  if  the  initiative  is  strict  and  imposes  very  specific 
charging  characteristics  (current  and  voltage)146.  An  SME  interviewed  for  the  impact 
assessment study welcomed the standardisation of charging solutions, as it would create a 
level playing field for companies.  

Specific sectors or regions: Few mobile phone manufacturers are based in the EU and they 
have only very small market share. In light of the fact that the vast majority of economic 
operators that would be potentially affected are not based in the EU, this initiative would 
not affect specific sectors or regions in the EU. 

145 approximately 160 million smartphones, 20% of which with a proprietary interface, and other 260 million 
electronic devices concerned electronic devices are annually sold on the EU market 
146 which is not the case, as discussed in section 8 

74 

 
                                                           
2.  SUMMARY OF COSTS AND BENEFITS 

A synopsis of the cost-benefit of the different policy options based on the considerations 
and the data in Annex 4 is reported below. In particular, tables 4.15-18 in Annex 4 can be 
summarised as follows, in absolute and relative values, with respect to the baseline.  

I. Overview of Benefits (total for all provisions) – Preferred Option  
Description 

Amount 

Comments 

Table 3.1 – Overview of Benefits 

Direct benefits 

Environmental benefits 

GHG emissions: 184 ktCO2e yearly 
Material use: 2606 tonnes yearly 
e-waste: 980 tonnes yearly 

Consumer benefits 

EUR 246 million yearly 

Economic benefits  

Indirect benefits 

EU  Manufacturers:  EUR  22  million 
yearly 
Retailers  and  Distributors:  EUR  457 
million yearly. 

Safety  of  products  on  the 
market 

Not quantifiable 

Notes:  

Incentivising  the  unbundling  of  EPS 
the 
(specific  objective  4)  brings 
biggest  influence  as  regard  to  the 
the  extraction  of 
reduction  of 
resources,  manufacture, 
transport, 
use and disposal of the chargers. 
The  harmonisation  of  the  connector 
at  the  device  (specific  objective  1) 
fast 
end  and 
charging  communication  protocol 
(specific  objective  2)  will  bring  a 
reduction  of 
the  purchases  of 
standalone EPS and cables. 

interoperability  of 

Worldwide  industries  are  affected 
negatively 

Reduction of purchases of standalone 
cables and EPS will indirectly reduce 
the  quantity  of  dangerous  products 
on the market. 

  As in section 2.4, the COVID crisis may have magnified the costs for manufacturers and the benefits for the society, 

although a quantitative estimate is not possible at the point of preparing this IA (September 2020) 

  Estimates are relative to the baseline for the preferred option as a whole 

II. Overview of costs – Policy Option 5 

Citizens/Consumers   Businesses 
One-
off 

Recurrent 

One-off 

Policy 
Option 
5  

Direct 
costs 

N/A 

N/A 

For  manufactures  who 
already  use  USB  Type  C  in 
the products in scope: N/A 

For manufactures who do not 
use  USB  Type  C  in  the 
products  in  scope:  Costs  to 
charging 
the 
redesign 
circuitry  of  the  equipment 
(mitigated  by  a 
transition 
period) 

75 

Administrations 

Recurrent 

One-off 

Recurrent 

N/A 

N/A 

N/A 

 
 
 
protocols 

For  manufactures  who 
currently use proprietary fast 
charging 
not 
compatible  with  USB  PD  or 
not  supporting  fast  charging 
at  all,  around  20%  of  the 
volumes  of  the  total  market: 
30  million  EUR  (0.6  EUR 
per device) 
For manufactures who do not 
use  USB  Type  C  in  the 
products in scope:  
Loss  of  royalties  for  which, 
unfortunately, data could not 
be gathered. 

By  the  combination  of  the 
measures, there will be a loss 
of  turnover  by  worldwide 
industries  of  367  million 
EUR  yearly compared to the 
baseline  

N/A 

N/A 

N/A 

Indirect 
costs 

N/A 

N/A 

Notes:  

  As in section 2.4, the COVID crisis may have magnified the costs for manufacturers and the benefits for the society, 

although a quantitative estimate is not possible at the point of preparing this IA (February 2021) 

  Estimates are relative to the baseline for the preferred option as a whole 

76 

 
 
 
 
 
ANNEX 4: ANALYTICAL METHODS 

1.  ENVIRONMENTAL ASSUMPTIONS AND CALCULATIONS  

Environmental  impacts  are  assessed  for  each  option  using  a  model  developed  by  the 
contractor, see Annexes F and G of the unbundling study147, to which we refer for all the 
details.  The essential element  is  that charger (EPS and cable) additions  and disposals  are 
modelled  each  year,  and  that  these  flows,  when  combined  with  impact  assumptions  are 
used  to  calculate  the  impacts.  In  this  section  we  present  the  approach  to  assessing  the 
environmental  impacts,  including  elaborating  the  assumptions  used  in  the  stock  model. 
Following  a  screening  of  main  environmental  impacts,  the  study  focuses  on  the  3  key 
environmental  impacts  of  EPS  and  cables,  namely:  (1)  use  of  raw  materials,  as  the 
production  of  chargers  consumes  metals,  plastics,  and  other  materials;  (2)  e-waste, 
generated  as  chargers  are  discarded;  and  (3)  greenhouse  gas  (GHG)  emissions  over  the 
life-cycle  of  the  chargers  (e.g.  manufacturing,  transport,  and  disposal  and  materials 
recovery). The following indicators are assessed: 

  Material  use  [tonnes]  –  calculated  in  the  stock  model  by  multiplying  additions  to 
the charger stock by a profile of the materials used. The profiles vary per EPS and 
cable type (weight and material content), and over time (modelling the introduction 
of more efficient, lighter materials). Material use can be split into the most relevant 
materials. 

  e-waste [tonnes] – calculated in the stock model as the weight of chargers disposed 
of each year. This is calculated by multiplying the number of units disposed by the 
material and weight composition of the charger component type. Sub-indicators on 
volumes of e-waste left untreated or recycled are also calculated. 

  GHG emissions [tonnes] – are calculated in the stock model as life-cycle emissions 
(cradle-to-grave)  per  charger  component  type,  accounted  in  the  year  of  sale. 
Emissions  are  calculated  on  the  basis  of  component  specific  emission  profiles 
multiplied by additions to the charger stock. 

Material use 

To measure material use a bill of materials (BoM) was developed following a bottom-up 
approach, as there was little or no useful new data (compared to the 2019 study148) in the 
available literature concerning the material contents of EPS or cables. The BoM considers 
all of the components contained in a mobile phone charger which allowed us to identify the 
heaviest and largest components (e.g., transformer, electrolytic capacitors, and transistors), 
based on the datasheets published by the manufacturers. Once the key components of the 

147 https://data.europa.eu/doi/10.2873/788086  
148 https://op.europa.eu/en/web/eu-law-and-publications/publication-detail/-/publication/c6fadfea-4641-11ea-
b81b-01aa75ed71a1  

77 

 
                                                           
EPS were identified, desk research were conducted to determine the materials used in each 
of  the  components.  Table  4.1  presents  the  standard  material  composition  of  a  mobile 
charger  and  cable  obtained  as  a  result  of  this  analysis.  In  preparing  this  composition  the 
information  about  the  materials  used  for  most  components  is  limited,  as  manufacturers 
generally do not include these details in the datasheets of the components.  

Table 4.1. Standard material composition of a mobile charger and cable 

Weight of components (g) 

EPS 

Cable 

Plastic 
Copper and copper alloys  
Stainless steel (USB connectors) 
Aluminium 
Others 
Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices 
(2021) 

30% 
30% 
24% 
- 
16% 

36% 
13% 
6% 
7% 
37% 

As  indicated  during  an  interview  with  a  supplier  of  high-performance  electronic 
components, it was estimated that the new technologies (e.g. GaN diodes, super-junction) 
would  enable  40%  less  volume  and  30%  less  weight  for  EPS,  through  improved  energy 
efficiency and reduction in heat, and therefore a reduction in insulation and other materials. 
Therefore, the refined stock model assumes that  the high-power and high-quality devices 
will  become  lighter  than  current  models  (per  wattage)  in  the  future.  Table  4.2  below 
presents the total weight per component type at 5 years intervals used in the analysis. 

Table  4.2.  Modelled  total  weight  per  component  type  (2015-2030)  based  on  input  from 
experts 

Component type 

2015 

2020 
Weight (g) 

2025 

2030 

EPS < 7.5 W 

7.5W <= EPS 
<=27W 

EPS > 27W 

Cable 

USB Type-A receptacle 
USB Type-C receptacle 
USB Type-A and Type-C receptacles 
(multi-port) 
USB Type-A receptacle 
USB Type-C receptacle 
USB Type-A and Type-C receptacles 
(multi-port) 
USB Type-A receptacle 
USB Type-C receptacle 
USB Type-A and Type-C receptacles 
(multi-port) 
Captive cable 
USB Type-A - USB Micro B plugs 
USB Type-A – USB Type-C plugs 
USB Type-A – proprietary (Lightning) 
plugs 

28 
28 

28 

50 
60 

102 

94 
117 

131 

113 
19 
34 

23 

28 
28 

28 

50 
60 

102 

94 
117 

131 

113 
19 
34 

23 

28 
28 

28 

45 
54 

92 

80 
99 

111 

96 
19 
34 

23 

28 
28 

28 

40 
48 

82 

66 
82 

92 

79 
19 
34 

23 

78 

 
 
USB Type -A – proprietary (Other 
device) plugs 
USB Type-C – USB Type-C plugs 
USB Type-C – proprietary (Lightning) 
plugs 
USB Type-C - proprietary (Other 
device) plugs 
USB Type-C plugs – wireless pad – Qi 
or other  

23 

45 

37 

37 

37 

23 

45 

37 

37 

37 

23 

45 

37 

37 

37 

23 

45 

37 

37 

37 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices 
(2021) 

Taking all the above into consideration, key assumptions related to the materials contained 
in the EPS and cables were made. The modelling inputs are described in detail in the study 
mentioned above. 

e-waste, treatment and recycling  

It is estimated e-waste volumes and sub-indicators on waste treatment and recycling in the 
stock model based on the average material composition of the chargers, the recyclability of 
the  materials,  the  volume  of  chargers  disposed  of,  the  method  of  disposal,  and  how 
disposed chargers are treated.  

To estimate the volume of EPS and cables disposed of every year, average values based on 
the responses to the consumer survey were considered. These suggested that approximately 
10% of the EPS and cables in stock are being disposed of each year. This assumption was 
applied  in  the  model  such  that  after  10  years  all  chargers  purchased  10  years  previously 
would  be  removed  from  the  stock.  A  share  of  the  EPS  and  cables  in  the  stock  would 
effectively be “in reserve”, i.e. functional, but stored and not in use. The consumer survey 
found that on average 1.32 EPS and 1.75 cables are reported to be held “in reserve”, whilst 
1.75 EPS and 2.05 cables are ‘in-use’. 

The volume of untreated and recycled EPS and cables was estimated considering WEEE 
disposal  and  treatment149  studies  which,  despite  many  data  gaps,  predict  increasing 
recycling rates over time. Based on analysis of the data for WEEE of small equipment and 
treatment in 2010 and 2018, an assumption for waste disposal and treatment was derived. 
This  estimates  for  2010  a  rate  of  41%  of  e-waste  being  sent  for  treatment,  increasing  to 
65% by 2018. An annual increment of 1.5% improvement in this rate is applied per  year 
based  on  this  historic  trend  and  an  assumption that  improvements  will tail  off  somewhat 

149 Key studies used as sources for this estimation, are Balde et al (UNITAR) (2020) In-depth review of the 
WEEE collection rates and targets in the EU-28, Norway, Switzerland and Iceland; and Balde et al 
(UNITAR) (2020) The Dutch WEEE flows 2020, what happened between 2010 and 2018? 

79 

 
 
                                                           
over  time  as  the  ‘low  hanging  fruit’  in  increasing  rates  is  used.  By  2030,  this  increase 
increment  sees  84%  of  charger  disposals  sent  for  treatment.  As  a  result  of  these 
assumptions, the share of untreated waste decreases from 35% in 2018 to 16% in 2030. 4.3 
below  presents  the  modelled  recycling  rates  at  5  years  intervals  used  in  the  analysis  (% 
recycled and %untreated waste). Additional key assumptions made related to the e-waste 
generated, treated and recycled are summarised in the consultant’s study150.  

Table 1.3 Modelled recycling rates for EPS and cables (2015-2030)  

2015  2020  2025  2030 
Disposal method 
56%  69%  76%  84% 
Disposed to recycling 
44%  31%  24%  16% 
Incorrectly disposed (untreated waste) 
Source:  Impact  assessment  study  on  Unbundling  of  mobile  phones 
and similar electronic devices (2021) 

Concerning  the  treatment  of  different  materials,  the  splits  of  materials  use  and  specific 
recycling rates assumed in the stock model are mainly based on the input provided during 
the interviews with recycling experts. 

Greenhouse Gas Emissions (GHG)  

GHG emissions are released over the full lifecycle of the chargers, starting from material 
extraction,  and  through  all  the  life-cycle  steps  of  manufacturing,  transport,  use,  and 
disposal. To consider the impact of these emissions, the first IA was mainly based on the 
results of the EU funded project SustainabilitySmart151, and other studies152 which focused 
on  specific  smartphone  models  and  their  accessories.  The  studies  provided  the  Global 
Warming  Potential  (GWP)  of  each  charger  component  (EPS  and  cable)  and  life-cycle 
phase  (e.g.  raw  material  acquisition,  manufacturing,  transport),  which  were  then  used  to 
calculate an average CO2 emissions impact per unit (g) of weight for the component types.  

It  is  to  be  noted  that  further  review  of  available  information  finds  only  very  limited 
additional  published  information  on  the  environmental  impact  of  chargers,  it  remains  an 
issue not widely addressed by LCA practitioners nor where companies publish their own 
results.  Therefore,  to  refine  the  GWP  values  considered  in  the  first  IA  study,  it  was 
considered  the  data  presented  in  the  framework  of  the  Eco-design  preparatory  study  on 

150 https://data.europa.eu/doi/10.2873/788086  
151  Sustainably  SMART  (2019)  Regulation  of  Common  Chargers  for  Smartphones  and  other  Compatible 
Devices: Screening Life Cycle Assessment. Policy Brief No. 2. 
152  Ercan,  M.  (2013),  Global  Warming  Potential  of  a  Smartphone  Using  Life  Cycle  Assessment 
Methodology;  Charles  River  Associates  (2015)  Harmonising  chargers  for  mobile  telephones  Impact 
assessment of options to achieve the harmonisation of chargers for mobile phones 

80 

 
 
                                                           
mobile  phones,  smartphones  and  tablets153.  Table  4.4  and  4.5  below  present  the  input 
values used by the updated stock model.  

Table 4.4 - Average GWP (kg CO2e per g of weight of component) 

Raw material and manufacturing 
Transport 
End of life 
Total 
Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices 
(2021) 
Table 4.5 - Average GHG emissions per unit of component 

EPS 
0.035 
0.031 
0.0003 
0.066 

Cable 
0.012 
0.023 
0.0002 
0.035 

Component type 

Average 
GHG 
emissions  (kg 
CO2e) 

EPS < 7.5 W 

EPS < 7.5 W 

EPS > 27W 154 

7.5W <= EPS <=27W 

USB Type-A receptacle 
USB Type-C receptacle 
USB Type-A and Type-C receptacles (multi-port) 
USB Type-A receptacle 
USB Type-C receptacle 
USB Type-A and Type-C receptacles (multiport) 
USB Type-A receptacle 
USB Type-C receptacle 
USB Type-A and Type-C receptacles (multiport) 
Captive cable 
USB Type-A - USB Micro B plugs 
USB Type-A – USB Type-C plugs 
USB Type-A – proprietary (Lightning) plugs 
USB Type -A – proprietary (Other device)plugs 
USB Type-C – USB Type-C plugs 
USB Type-C – proprietary (Lightning) plugs 
USB Type-C - proprietary (Other device) plugs 
USB Type-C plugs – wireless pad – Qi or other  
Source:  Impact assessment study on  Unbundling of mobile phones and similar electronic 
devices (2021) 

1.8 
1.8 
1.8 
3.3 
4.0 
6.7 
6.2 
7.7 
8.6 
7.4 
0.7 
1.2 
0.8 
0.8 
1.6 
1.3 
1.3 
1.3 

Cable 

153 Regarding the end-of-life (EoL) emissions, a positive GWP is based on high recycling rates (of packaging 
material)  and  high  rates  of  devices  being  reused.  For  this  assessment,  conservative  approach  was  favoured 
and, therefore, did not consider the value suggested by Task 5 for the EoL phase. Nonetheless, given that the 
contribution of the EoL phase to the overall emissions is very small compared to the other phases (<1%), it 
does not have a major influence on the overall results. 
154 GHG emissions per unit of EPS>27W will slightly decrease between 2020-2030, as a consequence of the 
decrease in weight for EPS > 27W  

81 

 
 
                                                           
During  the  scoping  phase,  potential  additional  impacts  from  unbundling  were  identified 
related  to  GHG  emissions.  For  instance,  not  including  an  EPS  and/or  cable  in  the  box 
could  reduce  the  size  of  the  packaging,  impacting  the  environment  in  three  main  ways: 
firstly, it may reduce the materials used in packaging (fibre and plastic); secondly, it may 
allow  for  more  devices  to  be  shipped  within  the  same  space,  hence  reducing  the 
environmental footprint of distribution, whilst the reduction in weight being shipped may 
also reduce the environmental impact; but, thirdly, shipping phones and EPS and/or cables 
separately may require additional distribution and delivery journeys, which would increase 
the  footprint.  An  analysis  of  these  factors  indicated  the  likelihood  that  their  impact  is 
considerably lower compared to the other life-cycle phases considered, and additional that 
there  are  substantial  uncertainties,  for  these  reasons  the  impacts  are  not  included  in  the 
main modelling and impact analysis.  

In brief, the main stock model inputs related to the estimation of GHG emissions include: 

  Material  and  weight  composition  of  the  EPS  and  cables  added  to  the  stock  every 

year, based on average material content profiles (as explained above)  

  Average CO2 eq emissions per weight of component (as presented in Table 4.4) 

Based on these inputs, the GHG  emissions (tonnes) are  calculated in  the  stock model on 
the basis of component specific weight and emission profiles multiplied by additions to the 
EPS and cables stock. An extended explanation of the modelling inputs input values used 
is provided in the study. 

2.  ECONOMIC ASSUMPTIONS AND CALCULATIONS  

The  following  types  of  impacts  were  identified  as  primary  for  this  Impact  Assessment: 
Operating  costs  and  conduct  of  business;  administrative  burdens  on  businesses; 
competitiveness  of  businesses,  innovation  and  research;  and  impacts  on  consumers  and 
households. The initiative may give rise to non-tariff barriers (e.g. if manufacturers cannot 
sell mobile phones using proprietary charging solutions) and it may also affect regulatory 
convergence with  third countries (e.g. if a third country regulates for the use of different 
charging technologies).  However, all policy  options are based on international  standards, 
meaning these impacts (if any) are expected to remain limited. The position of SMEs was 
also  considered  of  low  relevance,  since  most  economic  operators  in  the  sector  are  big 
companies  located  in  third  countries.  A  minority  of  European  SMEs  (those  that  supply 
charging  solutions  to  phone  manufacturers)  could  though  be  affected.  This  impact, 
although continues to be minor, is investigated in this study. 

As a result, we focus the assessment on the following types of impacts: 

Innovation and research; 

  Competitiveness of businesses; 
 
  Costs for consumers; 
  Operating costs and conduct of business; 
  Costs to public authorities; 

82 

 
  Macroeconomic impacts (including impacts on SMEs). 

Competitiveness of businesses  

The  policy  options  considered  may  affect  competitiveness  in  several  ways.  For  instance, 
some  connectors  are  more  expensive  than  others,  and  mandating  USB  Type-C  may 
increase the cost of lower-end devices that still use USB micro-B connectors. The options 
that consider unbundling, on the other hand, would affect the overall cost of the product, 
and it is still unclear whether savings from not including chargers in the box will be passed 
on to consumers, or absorbed by the industry. Finally, some manufacturers receive income 
from the sale of proprietary charging solutions/accessories. Their income may be affected 
if standard solutions are mandated. 

Therefore, this type of cost encompasses four different effects: 

  Revenues and/or costs generated from the production and sale of chargers that have 

different characteristics than in the baseline scenario; 

  Reduction in the number of chargers sold in the EU market; 
  Changes  to  the  distribution  of  revenue  among  competitors,  due  to  harmonisation 

and/or unbundling of chargers; 

  Variations in income from receiving/paying royalties. 

83 

 
Table 4.6 - Impact on businesses, per type of stakeholder  

Stakeholder 

Differences in costs 

Fewer chargers sold 

Manufacturers 
of  System  on 
a Chip (SoC) 

Currently,  manufacturers 
of  SoC 
already 
are 
in 
including  USB  PD 
their  chips.  It  may  affect, 
however,  the  cost  of  SoC 
for lower-end devices. 

Manufacturers 
mobile 
of 
and 
phones 
other  portable 
devices 

in 

cost 
Differences 
among 
different 
technologies  are  assumed 
to  be  passed  on 
to 
consumers. 

Manufacturers 
of chargers 

in 

cost 
Differences 
different 
among 
technologies  are  assumed 
to  be  passed  on 
to 
consumers. 

Not applicable 

The  unbundling  options  would  generate 
savings for manufacturers, as they would 
not need to include EPS and/or cables in 
the  box  anymore.  Some  of  these  savings 
may  be  passed  on  to  consumers  through 
reductions in the price of the device, but 
some may be absorbed by manufacturers 
as additional income. 

The  unbundling  options  will 
likely 
reduce  the  total  number  of  chargers  sold 
in 
all 
and 
manufacturers  of  chargers  selling  in  the 
EU will be affected.  

the  EU, 

therefore 

Changes in distribution of revenue among 
competitors 

Variations in income from royalties 

The  battery  charging  protocol  is  only  a  small 
component of the chip. It is not expected that any 
of  the  options  would  produce  changes  in  the 
distribution of revenue. 

The  options  considered  allow  the  use  of 
proprietary  charging  protocols,  as  long  as 
USB  PD  is  also  included.  Therefore,  no 
losses of income from royalties are expected 
for SoC manufacturers.  

charging 

technologies  offer 

Some  manufacturers  argue  that  their  proprietary 
fast 
a 
mandatory 
competitive 
standardisation  or  unbundling  would  affect  their 
competitive position. 

advantage, 

them 

and 

With  unbundling  options,  firms  who  produce 
chargers  to  be  sold  in  the  box  may  lose  market 
share if they are not able to adapt their distribution 
networks  rapidly.  This  share  would  be  won  by 
manufacturers 
to 
retailers/consumers.  Harmonisation  options  may 
also  trigger  a  reduction  of  sales  of  proprietary 
benefit 
chargers 
manufacturers of standard charging solutions. 

that  would 

distribute 

cables 

who 

and 

Manufacturers  of  devices  using  proprietary 
connectors may lose incomes from royalties 
(e.g.  sale  of  compatible  accessories)  if 
connectors are standardised. 

Harmonisation options would lead to further 
adoption of USB PD / USB Type C than in 
the  baseline,  which  may  incentivise  some 
firms  to  stop  manufacturing  proprietary 
solutions.  This  would  lead  to  a reduction  in 
royalty fees that charger manufacturers pay. 
As  this  is  a very  concentrated  market,  it  is 
expected  that  marginal  reductions  in  costs 
would  be  passed  on  to  consumers,  rather 
than producing gains for manufacturers. 

Distributors, 
retailers,  and 
wholesalers 

major 

No 
expected 

impacts 

Distributors  may  benefit 
the 
increased sales of stand-alone chargers (if 
their revenue is higher than when sold in 
the box) 

from 

No major impacts expected 

No major impacts expected 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

84 

 
These effects are summarised below, per type of stakeholder affected. 

A key aspect when assessing economic impacts concerned the savings from not including chargers in the 
box (for options that consider unbundling) which could be reflected in the retail price of the devices or 
whether they will be absorbed as additional income by manufacturers.  

In the online survey of stakeholders, two thirds of industry stakeholders (64%) answered that it is very 
unlikely or quite unlikely that the average retail price of mobile phones will decrease in the short term if 
the EPS is not included in the box, and the majority (57%) were of the same view when considering the 
effects in the long term. 

Another  key  aspect  is  whether  manufacturers  will  offer  EPS  out  of  the  box  at  a  reduced  price  if 
unbundling becomes mandatory. In the survey, just over half of respondents (54%) thought this is quite or 
very unlikely. However, in interviews, manufacturers who have started to unbundle commented that they 
have reduced the price of their stand-alone EPS.155 

In  the  model,  it  has  been  assumed  that  the  savings  of  selling  mobile  phones  unbundled  from  the 
EPS/cable  are  passed  on  to  consumers.  In  the  premium  segment  of  the  market  this  might  not  be  so 
obvious,  as  prices  are  not  (only)  determined  by  marginal  costs  but  instead  by  market  positioning 
strategies. However, evidence suggests that manufacturers are likely to offer other “accessories” instead 
(e.g.  HMD  is  extending  the  guarantee  of  the  device  by  one  year).  The  price  in  medium  and  low  tier 
phones is largely determined by the marginal price, and therefore it is to be expected that when savings 
are achieved from not including chargers in the box, these are passed on to consumers. 

This  impact  has  been  quantified  through  the  stock  model.  The  following  table  presents  an  aggregate 
summary of the influences of each measure on the evolution of chargers sales split by EPS and cables. 
This shows the annual additions to the charger stock based on chargers provided with smartphones and 
chargers purchased standalone. 

Table 4.7 - Standalone EPS sales projections [million units] 

Measure 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2030 difference 
with baseline 

Baseline 
Harmonise device-end connectors 
Support of the relevant protocol on 
the end-device 
Making available on the market at 
least unbundled solutions 
Informing consumers about 
charging performance 

Source: Consultant calculations  

129.2  129.8  130.0  130.2  130.3  130.5  130.6  130.2 
129.2  129.8  130.0  130.2  130.3  130.5  130.6  130.2 

130.3  125.7  125.9  126.1  126.2  126.4  126.5  126.2 

129.2  154.7  154.2  153.7  153.3  152.8  152.4  151.5 

129.2  127.7  127.9  128.0  128.1  128.3  128.5  128.1 

0% 

-3% 

16% 

-2% 

155  As  of  18  January  2021,  customers  purchasing  an 
in  Spain 
(https://www.apple.com/es/shop/buy-iphone/iphone-12)  were  offered  a  20W  USB-C  EPS  as  an  optional  accessory  for  €25. 
Similarly, 
Spain 
(https://www.samsung.com/es/smartphones/galaxy-s21-5g/buy/)  were  offered  a  25W  USB-C  EPS  for  €24.90.  During 
interviews,  both  Apple  and  Samsung  reported  they  had  reduced  the  price  of  these  EPS  as  part  of  their  recent  unbundled 
launches. 

the  Apple  online  shop 

pre-ordering 

a  Galaxy 

iPhone  12 

customers 

Samsung 

online 

from 

from 

shop 

S21 

the 

in 

85 

 
 
                                                           
Table 4.8 - Standalone cable sales projections [million units] 

Measure 

2023 

2024 

2025 

2026 

2027 

2028 

2029 

2030 

2030 
difference 
with baseline 

Baseline 
Harmonise 
device-end 
connectors 
Support of 
the relevant 
protocol on 
the end-
device 
Making 
available on 
the market at 
least 
unbundled 
solutions 
Informing 
consumers 
about 
charging 
performance 

138.7 

138.9 

139.0 

139.0 

139.1 

139.1 

139.1 

138.4 

138.7 

132.7 

132.8 

132.9 

132.9 

132.9 

133.0 

132.3 

-4% 

138.7 

135.8 

135.9 

136.0 

136.0 

136.1 

136.1 

135.4 

-2% 

138.7 

138.9 

139.0 

139.0 

139.1 

139.1 

139.1 

138.4 

0% 

138.7 

137.5 

137.6 

137.6 

137.7 

137.7 

137.8 

137.0 

-1% 

Source: Consultant calculations 

Figure 1.1: Anticipated impacts of mandatory unbundling as perceived by industry stakeholders 

Percentage of respondents
0% 10% 20% 30% 40% 50% 60% 70% 80% 90%100%

The market for EPS for mobile phones would become more
competitive (i.e. more suppliers, increased pressure to reduce
prices and/or offer better products).

Most mobile manufacturers would reduce the retail price of their 
branded stand-alone EPS (compared to the “pre-decoupling” 
price of an equivalent stand-alone EPS).

Most  mobile manufacturers would offer an EPS at a discount
(compared to the normal stand-alone price) to customers
purchasing a new mobile phone.

Most mobile manufacturers would offer a greater variety of EPS
for purchase than would have been the case without
decoupling.

In the short term (first 1-2 years after decoupling becomes
obligatory), most major mobile manufacturers would reduce the
retail price of their mobile phones (to compensate for the fact…

In the medium to longer term (3-5 years after decoupling
becomes obligatory), the average retail price of mobile phones
would be lower than it would have been if EPS were still…

To comply with decoupling obligations, most mobile phone
manufacturers would have to make significant changes to their
business models and/or processes

To comply with decoupling obligations, most mobile phone
distributors would have to make significant changes to their
business models and/or processes.

21%

25%

32%

11%

11%

11%

29%

39%

7%

14%

7%

21%

43%

11%

18%

7%

18%

61%

4%

11%

4%

18%

39%

25%

14%

4%

25%

32%

25%

14%

25%

18%

29%

21%

7%

11%

25%

32%

21%

11%

Very likely

Quite likely

Quite unlikely

Very unlikely

Don’t know

Source: stakeholder survey. N=28, all private sector respondents 

It  is  assumed  that,  when  EPS  and  cables  are  sold  bundled  with  mobile  phones,  they  are  sold  at  the 
wholesale  price  (industry  representatives  interviewed  in  this  and  the  first  IA  assured  that  they  do  not 

86 

 
 
 
obtain  any  profits  for  the  sale  of  bundled  EPS).  When  EPS/cables  are  not  bundled  to  mobile  phones, 
consumers save the wholesale price of the charger; however, if they  buy an EPS/cable separately, they 
pay the retail price. That is why, even when there are fewer chargers in the market, consumers might not 
obtain any savings. Their capacity to obtain savings will depend on the effectiveness of unbundling (i.e. 
how many consumers would continue buying EPS). 

The revenue for producers is assumed to be the difference between the price paid by consumers and the 
production cost. The stock model does not assign the revenue across the supply chain, but this is assessed 
qualitatively. 

The  gross  profit  generated  via  the  sale  of  chargers  (both  in  the  box  and  stand-alone)  for  each  policy 
option has been estimated, and it  was  compared  to  the  gross profit in  the baseline, using the  following 
formula: 

GPPOj = ∑(Pi×Qi)+ ∑(SPi×SQi) - ∑(Ci×Qi) - ∑(Ci×SQi) 

Where: 

  GPPOj = Gross profit for manufacturers in Policy Option j 
  Pi = Price of type of charger I (EPS/cable) when sold in the box 
  Qi = Quantity of type of charger i (EPS/cable) sold in the box 
  SPi = Price of type of charger i (EPS/cable) when sold as a standalone charger 
  SQi = Quantity of standalone chargers sold of type i (EPS/cable) 
  Ci = Production cost of manufacturing a charger of type i (EPS/cable) 

Prices per type of product have been determined as follows: first, the study team conducted a mapping of 
all types of cables and EPS in retail websites. An average retail price was then calculated per product. A 
similar exercise was conducted for the wholesale prices. The estimate is that, on average, the wholesale 
price is 45% of the retail price. In other words, the retail price is 2.2 times the wholesale price. Estimating 
production  costs  required  a  different  approach,  as  this  is  not  public  information.  In  interviews,  it  was 
asked manufacturers about the production costs or their products, and about differences in production cost 
between,  e.g.  USB  Type-C  interfaces  and  USB  micro-B  interfaces.  The  estimate  is  that  the  production 
cost is, approximately, 20% of the retail price. In other words, the retail price is 5 times the production 
cost. The table below details the prices used in the impact assessment. The quantities are derived from the 
stock model. 

Table 4.9. Assumed costs and prices of chargers 

Product 

Type of product 

EPS <7.5W 

EPS 7.5-
27W 

EPS >27W 

USB Standard-A receptacle 
USB Type-C receptacle 
Multiport 
USB Standard-A receptacle 
USB Type-C receptacle 
Multiport 
USB Standard-A receptacle 
USB Type-C receptacle 

87 

Production 
cost (€) 

Price when 
in the box 
(€) 

3.3 
3.0 
3.0 
3.0 
4.8 
5.5 
6.0 
6.4 

5.8 
5.3 
5.3 
5.2 
8.4 
9.6 
10.5 
11.2 

Stand-
alone 
price 
(€) 

16.7 
15.0 
15.0 
15.0 
24.0 
27.4 
30.0 
32.0 

 
Multiport 
Captive cable 
USB Standard-A - USB Micro-B 
USB Standard-A - USB Type-C 
USB Standard-A – proprietary (Lightning) 
USB Type-C - USB Type-C 
USB Type-C – proprietary (Lightning) 

7.6 
5.5 
1.4 
1.9 
5.0 
2.8 
5.0 

13.3 
9.6 
2.5 
3.3 
8.8 
4.9 
8.8 

38.1 
27.5 
7.0 
9.5 
25.0 
14.0 
25.0 

Cables (1m) 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

It  should be noted that the prices have kept  constant  over time in the model. However, interviews with 
experts  and  industry  representatives  suggest  that  the  cost  and  price  of  USB  Type-C  connectors  will 
decrease over time, as more devices incorporate this connector and more economies of scale are achieved.  

Other impacts on competitiveness, i.e. changes in distribution of revenue among competitors and loss of 
income from royalties, are explored qualitatively due to the lack of certain information in that respect. 

Innovation and research 

The  initiative  may  affect  innovation  in  charging  technologies  that  are  not  compliant  with  the  policy 
options (e.g. innovation in new connectors or fast charging technologies). Innovations may be pursued in 
a  collaborative  environment  to  develop  new  standards  (e.g.  the  USB-IF),  or  by  private  companies 
individually to obtain new sources of comparative advantage. The new regulation or voluntary agreement 
on  harmonisation  could  be  updated  to  incorporate  new  standards,  but  not  proprietary  charging 
technologies.  

Given the size of the EU market, a regulation that prohibits proprietary charging technologies to be placed 
in  the  EU  market  may  preclude  private  companies  from  investing  in  this  type  of  innovation  (i.e.  not 
cooperative). Under the voluntary agreement, companies would voluntarily commit, but not be obliged, to 
remove  proprietary  charging  technologies  from  their  phones,  which  means  they  would  not  be  de-
incentivised (or not to the same extent) from investing in new technologies. 

The  development  of  the  USB  Type-C  connector  may  serve  as  an  illustrative  example.  During  the 
conducted  interviews,  it  was  widely  recognised  by  the  industry  that  the  development  of  USB  Type-C 
connectors  was  influenced  (and  to  some  extent  facilitated)  by  the  existence  of  Lightning.  In  particular, 
industry  commented that some features of  Lightning, including the fact  that it is reversible, found their 
way into the USB Type-C connector. By  extension, it appears plausible that the development  of future 
USB  technology  could  be  negatively  affected  by  the  absence  of  any  competing  connector  technologies 
whose features could eventually be incorporated. 

Businesses’ capacity to innovate, in this case, is also linked to their competitiveness. In fact, as explained 
in section 2 (problem definition), fast charging solutions are a source of competitive advantage for some 
companies. 

The significance of this impact will depend on the chosen policy instrument, with higher negative impacts 
if the instrument is a regulation (as opposed to a voluntary agreement). It should be noted that companies 
innovating in charging solutions are not based in the EU. This impact is analysed qualitatively. 

88 

 
Impacts on consumers 

Impacts on consumers are primarily assessed in the sections dedicated to “social impacts”. As explained 
above when describing the impacts on competitiveness, the policy options may require the use of certain 
inputs  (e.g.  USB  Type-C  connectors)  or  unbundling  the  chargers,  which  would  have  an  impact  on  the 
price consumers pay when acquiring a new mobile phone. This impact is quantified following the same 
approach as for impacts on competitiveness. 

The price that consumers will pay for their chargers, whether included in the box or bought separately, 
will  be  affected  by  the  policy  options,  in  the  same  way  that  the  options  affect  the  gross  profit  that 
manufacturers receive. The formula to calculate the cost for consumers is as follows: 

CPOj = ∑(Pi×Qi)+ ∑(SPi×SQi) 

Where: 

  CPOj = Cost for consumers in Policy Option j 
  Pi = Price of type of charger i when sold in the box 
  Qi = Quantity of type of charger i sold in the box 
  SPi = Price of type of charger i when sold as a standalone charger 
  SQi = Quantity of standalone chargers sold of type i 

Operating costs and conduct of business  

Operating costs and conduct of business refer to additional adjustment, compliance or transaction costs on 
businesses derived from  the policy options.  It may affect,  inter alia, the cost or availability of essential 
inputs,  access  to  finance,  the  investment  cycle,  or  entail  the  withdrawal  of  certain  products  from  the 
market.  

One  of  the  costs  considered  is  the  cost  of  demonstrating  compliance  with  the  standard  or  regulation  in 
question (conformity assessment). The costs vary substantially depending on the type of regulation (e.g. 
essential requirement, harmonised standard…) and on the option  given to  /  chosen by manufacturers to 
demonstrate  compliance  (e.g.  presumption  of  conformity,  or  other  methods).156  The  impact  will  also 
depend  on  whether  the  policy  options  require  full  compliance  with  a  standard,  or  compatibility  (e.g. 
essential requirements).  

The USB IF has a compliance programme to certify sinks (devices) and sources (EPS) that are compliant 
with the USB PD 3.0 specification. Manufacturers may also test whether their own products are USB PD 
compatible. There are products in the market that claim to perform this test, with a cost of circa 600 Euros 
before tax.157 

156 More information on conformity assessment is available at: https://ec.europa.eu/growth/single-market/goods/building-
blocks/conformity-assessment_en  
157 See, for instance: https://evision-webshop.de/USB-Power-Delivery-Tester/en  

89 

 
                                                           
In addition, mandating certain standards may create market barriers and produce distortions (e.g. if other 
countries  apply  different  requirements  or  standards),  forcing  manufacturers  to  have  different  models  or 
designs for each market. 

This  impact  is  assessed  qualitatively based on information  provided by interviewees across all types of 
stakeholders, and on literature review. 

Table 4.10 – information from stakeholders 

Type of stakeholder 

Manufacturers of mobile 
phones  

Distributors, retailers and 
wholesalers 

Manufacturers of chargers 
(EPS and/or cables) 

Manufacturers of System-
on-Chip (SoC) 

initiatives.  If  unbundling 

How they may be affected 
All  the  policy  options  considered  require  manufacturers  making 
changes in their devices (e.g. to include USB Type C connectors and/or 
USB PD as the charging battery protocol), or changes in their packages 
(to remove the EPS and/or the cable, for those cases where accessories 
are  still  included).  Manufacturers  may  also  need  to  demonstrate 
compliance  with  standards  (USB  Type  C  and/or  USB  PD)  in  their 
devices and the EPS included in the box.  
The  options  that  include  unbundling  may  affect  distributors,  as  they 
may have to look for new suppliers of stand-alone EPS and/or cables. 
They may also need to upskill their staff to be able to provide advice to 
consumers on which EPS/cable works with their devices. 
Manufacturers  of chargers of  portable  devices  would also be  affected 
by  unbundling  and  harmonisation 
is 
mandated,  they  may  have  to  find  new  intermediaries  to  sell  their 
EPS/cables.  Firms  that  manufacture  the  chargers  that  are  currently 
included  in  the  box  with  mobile  phones  and  other  devices  would  be 
particularly  affected.  In  interviews  with  the  industry,  it  has  become 
apparent  that  there  are  some  charger  manufacturers  specialised  in 
designing  and  producing  tailor-made  EPS  and  cables  for  specific 
portable  devices.  Chargers  are  produced  and  sold  unbranded  to 
manufacturers of portable devices, who incorporate their own brand to 
the final product.  
Harmonisation of EPS, on the other hand, would affect those firms that 
are  currently  manufacturing  chargers  with  proprietary  charging 
protocols,  as  they  would  need  to  adapt  their  processes  to  incorporate 
standard protocols (if not incorporated yet). Manufacturers of chargers 
may  need  to  perform  new  tests  or  obtain  new  certifications  on  their 
EPS (e.g. on USB PD compliance). 
A  system  on  a  chip  (SoC)  is  an  integrated  circuit  (also  known  as  a 
"chip") that integrates all or most components of a computer or other 
electronic  system.  These  components  almost  always  include  a  central 
processing  unit  (CPU),  memory,  input/output  ports  and  secondary 
storage, often alongside other components such as radio modems and a 
GPU – all on a single substrate or microchip. The SoC determines the 
battery charging protocol used by electronic devices. 
Manufacturers  of  SoC  generally  include  USB  PD  along  with  other 
proprietary solutions.  

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

90 

 
Costs to public authorities  

Costs to public authorities may arise in two ways: 

  Cost  of  adapting  standards  (e.g.  IEC  63002)  to  the  requirements  of  the  EU  regulation  (e.g. 
defining minimum requirements that firms need to comply with, based on the standard). This cost 
is expected to be low / negligible, as existing standards would be used for any policy option. 
Increase  in  control  costs  for  surveillance  authorities  to  check  an  additional  standard.  Given  that 
control and surveillance systems are already in place, the marginal cost for testing any additional 
requirement is expected to be very low or negligible.  

 

This impact, which is considered to be very minor, is assessed qualitatively.  

Macroeconomic impacts and impacts on SMEs 

Most of the companies in the supply chain of mobile phones and their chargers are located out of the EU. 
There are very few manufacturers of mobile phones headquartered in the EU (notably, HMD, Fairphone 
as well as other small companies specialised on mobile phones for specific segments of the population), 
and  their  production  lines  are  located  overseas  in  most  cases.  The  impacts  for  EU-based  mobile  phone 
manufacturers  are  assessed  qualitatively.  The  market  of  chargers  is  more  fragmented  (i.e.  formed  by  a 
larger number of companies), with some companies manufacturing chargers in the EU. There are around 
10,000 companies manufacturing “other electrical equipment” in the EU (NACE 2790)158, of which it is 
estimated that around 1% (100 firms) manufacture power supply units for telecommunication apparatus. 
Through the stock model, it is estimated that their turnover in 2020 was 154 million EUR (including only 
turnover from sales of chargers).159 On average, between 2012 and 2018, there was one person employed 
in the EU in the manufacture of EPS per 186,177 Euros of turnover.160 In other words, there were around 
1,900 people in the EU employed in the production of chargers.  

Regulations that affect the overall number of sales of EPS and cables in the EU would affect the firms’ 
turnover  and,  therefore,  may  have  wider  macroeconomic  implications  on  production  and  employment. 
These effects have been modelled in the stock model, where differences in revenues between the policy 
options and the baseline have been used as an input to estimate effects on EU employment.  

Model assumptions of each measure 

Measure 1: Harmonise device-end connectors  

The following table presents an aggregate summary of the measure 1 scenario evolution of chargers split 
by EPS and cables. This shows the annual additions to the charger stock based on chargers provided with 
smartphones  and  chargers  purchased  standalone.  The  key  impact  of  this  option  is  that  all  smartphones 
must  have  USB  Type-C  connection  ports,  cables  supplied  with  phones  would  alter  to  align  with  this 

158 Source: Structural Business Statistics (SBS), Annual detailed enterprise statistics for industry (NACE Rev. 2, B-E) 
[sbs_na_ind_r2]. Extracted on 8 March 2021 for NACE 2790 Manufacture of other electrical equipment. 
159 Chargers’ manufacturers’ turnover is estimated by multiplying the amount of chargers in the baseline that are produced in 
the EU (26% of standalone chargers, according to PROCOM data) by the wholesale price of chargers. 
160 Source: Structural Business Statistics (SBS) Extract for NACE 2790 Manufacture of other electrical equipment. 

91 

 
                                                           
change. In summary, the assumptions underlying this scenario are the same as the baseline except for the 
following variations: 

  With  smartphones  there  is  no  variation  in  total  additions  of  EPS  or  cables  compared  to  the 
baseline  as  these  are  directly  linked  to  smartphone  sales  which  remain  unchanged  across  policy 
options.  Changes  in  EPS  and  cables  types  supplied  with  smartphones  do  occur  with  the  main 
variations from the baseline including: 

o  EPS – types: The option requires a switch to USB Type-C on the phone, and the change to 
cables with USB Type-A to Type-C cables (see below), is expected to also indirectly lead 
to  an  increase  in  wattage  of  EPS  to  the  7.5W  <=  EPS  <=27W  bracket  as  manufacturers 
take  advantage  of  the  faster  charging  possibilities  of  USB  Type-C  compared  to  USB 
Micro-B.  This  is  modelled  by  a  reduction  of  the  baseline  share  of  EPS  USB  Type-A 
<7.5W to zero, with this share being redistributed to the EPS USB Type-A 7.5W <= EPS 
<=27W category from 2024 onwards. 

o  Cables - types: both USB micro-B and Lightning (all Type-C in the baseline from 2021) 
cables are modelled to be reduced to zero in 2024 on introduction of the policy. In 2023 
these cable types are already reduced by half compared to  the baseline as manufacturers 
begin to adjust. The displaced market shares are allocated, first the Lightning cable share is 
all reallocated to USB Type-C – Type-C cables. Whilst the USB Type-A to Micro-B cable 
share  is  redistributed  to  USB  Type-A  –  Type-C,  and  USB  Type-C  –  Type-C  cables,  but 
predominantly  the  former  given  the  configuration  of  the  EPS  still  also  supplied  with 
smartphones,  and  the  likelihood  that  for  cost  reasons  manufacturers  still  producing  USB 
Micro-B in 2024 will revert to USB Type-A – Type-C cables as the cheapest alternative. 
The C:C share of this displacement is around 12% in 2024, increasing to 29% by 2030.  

  Standalone charger sales are modelled on the basis described above, and with variations in types 

compared to the baseline including:  

o  EPS - sales: no change in totals compared to baseline. 

o  EPS – types: Similar to the with smartphone sales, the move to USB Type-C connectors 
also leads to a faster reduction in <7.5W EPS than in the baseline, reducing from 6% of the 
total in 2024 (baseline 9%) to 0.5% by 2030 (baseline 5%). These displaced sales are split 
between EPS USB Type-A and USB Type-C on the basis of their share of cable sales with 
smartphones in the same year.  

o  Cables  –  sales:  the  requirement  for  harmonised  device-end  connectors,  will  particularly 
impact  the  purchase  of  cables  with  proprietary  connectors,  namely  the  Lightning 
connectors of  Apple. An impact  on total cable sales is  assumed due to the results of the 
consumer  survey  which  show  that  Apple  users  have  a  higher  propensity  than  average  to 
purchase standalone cables, which would no longer be necessary under this policy option.  

92 

 
Annual sales (with Smartphones + standalone) [units] 

Stock [units] 

Figure 4.2: Measure 1 scenario evolution 2017-2030 

EPS 

Cables 

Source: Consultant own stock model calculations.  
Note: The No EPS area in the stock graph does not decline as there are no disposals assumed (unlike other EPS), the total accumulates for this reason. 

93 

 
 
 
 
 
 
o  A reduction of 27% is applied to the share of the market of Apple (17.8%) to model this 
effect,  this  effectively  reduces  the  0.41  cables  per  person  per  year  ratio  to  0.39,  which 
represents a 4.8% reduction in sales compared to the baseline. 

o  Cables - types: Significant reduction in all non USB Type-C cables from 2024 although 
some residual sales for older phones remain. USB Micro-B cables declining to 1% market 
share by  2027  (by 2030  in  baseline).  Lightning cables are  reduced to 2% of the total  by 
2027.  Displaced  sales  split  in  proportion  to  the  smartphone  market,  i.e.  47:53  between 
Type-A-C  and  Type-C-C  cables  in  2024,  increasing  to  45:55  to  C-C  cables  by  2030.  In 
total by 2030 USB Type-A – Type-C cables account for 34% of the market, whilst USB 
Type-C – Type-C cables 63%, legacy Lightning and Micro-B cables the small remainder. 

Measure 2: Require mobile phones to be compatible with USB PD 

The following table presents an aggregate summary of the measure 2 scenario evolution of chargers split 
by EPS and cables. This shows the annual additions to the charger stock based on chargers provided with 
smartphones  and  chargers  purchased  standalone.  The  key  assumptions  underlying  this  scenario  are  the 
same as the baseline except for the following variations: 

  With  smartphones  there  is  no  variation  in  total  additions  of  EPS  or  cables  compared  to  the 
baseline  as  these  are  directly  linked  to  smartphone  sales  which  remain  unchanged  across  policy 
options.  Changes  in  EPS  and  cables  types  supplied  with  smartphones  do  occur  with  the  main 
variations from the baseline including: 

o  EPS - types: The same as for option 1, a requirement for USB-PD compatibility leads to a 
move away from low power (<7.5W) EPS, with these reduced to zero from 2024 as EPS 
are made more powerful to take advantage of the required USB Type-C charging.  

o  Cables  -  types:  The  requirement  for  USB-PD  compatibility  results  in  all  non-Apple 
phones that were still using USB Micro-B in the baseline (8.6% in 2024) switch to USB 
Type-C to ensure compatibility. In 2023 USB Micro-B cables are already reduced by half 
compared to the baseline as manufacturers begin to adjust. The displaced market share is 
allocated in the same way as Option 1 between USB Type-A–Type-C, and USB Type-C–
Type-C cables. 

  Standalone  charger  sales  are  modelled  on  the  basis  described  above  in  Figure  4.2,  and  with 

variations in types compared to the baseline including:  

o  EPS – sales: are reduced by the policy measure (-4% by 2030) compared to the baseline. 
This results from an assumed reduction in standalone sales to consumers that purchased a 
new  EPS  to  acquire  a  faster  charger,  as  the  requirement  for  USB-PD  compatibility,  as 
described  above,  is  expected  to  lead  to  a  higher  proportion  of  fast  chargers  supplied  as 
standard with smartphones and/or that other standalone chargers are more likely to be able 
to  fast-charge  any  phone.  It  is  applied  in  the  model  through  a  reduction  in  the  ratio  of 
people  assumed  to  purchase  an  EPS  (0.31  per  person/per  year  in  the  baseline),  with  a 
reduction  of  5%  applied  to  this  ratio,  reflecting  the  proportion  of  those  in  the  consumer 
survey for the 2019 study that reported buying a standalone charger for the purpose of fast 
charging capabilities.  

o  EPS – types: This options affects EPS types in exactly the same way as option 1, with a 
faster reduction in <7.5W EPS than baseline, reducing to 0.5% by 2030. Displaced sales 
split between EPS USB Type-A and USB Type-C. 

o  Cables  –  sales:  this  option  is  not  expected  to  directly  influence  standalone  cable  sales. 
However, as described above, they are expected to result in a reduction in standalone EPS 
sales  of  approximately  5%.  This  is  also  assumed  to  have  an  impact  on  cable  sales  as  a 
share  of  EPS  sales  will  be  for  EPS  and  cables  bundled  together.  The  consumer  survey 

94 

 
provided  information  to  estimate  that  62%  of  EPS  purchased  standalone  were  purchased 
with cables. This ratio is applied to the 5% assumption on EPS reductions, resulting in a 
3.1% reduction in cable sales compared to the baseline.  

o  Cables - types: Significant reduction in remaining USB Micro B cables from 2024. Some 
residual sales for older phones remain. USB Micro-B cables declining to 1% by 2027 (by 
2030  in  baseline).  Micro-B  displaced  sales  split  in  proportion  to  the  smartphone  market 
47:53 between A-C and C-C cables in 2024, increasing to 45:55 to C-C cables by 2030. In 
total by 2030 USB Type-A – Type-C cables account for 24% of the standalone market by 
2030, whilst USB Type-C – Type-C cables 50%. 

Measure 3: Mandatory unbundling of EPS 

The following table presents an aggregate summary of the measure 3 scenario evolution of chargers split 
by EPS and cables. This shows the annual additions to the charger stock based on chargers provided with 
smartphones  and  chargers  purchased  standalone.  The  key  assumptions  underlying  this  scenario  are  the 
same as the baseline except for the following variations: 

  With  smartphones  there  is  a  key  variation  in  total  additions  of  EPS  or  cables  compared  to  the 
baseline, with EPS additions reduced to zero by this policy option. Purchases of EPS at the same 
time as a phone are added to standalone sales. No variations in cables additions are expected. For 
EPS and cable types: 

o  EPS  –  types:  All  EPS  unbundled  from  2024  onwards,  this  results  in  around  60  million 

fewer EPS being supplied with smartphones each year. 

o  Cables – types: No variation from baseline types.  

  Standalone  charger  sales  are  modelled  on  the  basis  described  above  in    Figure  4.2,  and  with 

variations in types compared to the baseline including:  

o  EPS - sales: show a significant increase in this option of +16% or around 22 million per 
year by 2030. This  is  solely due to  the mandatory  unbundling of all smartphones, which 
creates a larger number of ‘rebound’ standalone purchases, added at the net ratio of 0.39 
per unbundled phone as described previously for the baseline. 

o  EPS – types: No changes compared to the baseline, EPS type splits remain the same, only 

the numbers of EPS are significantly increased. 

o  Cable – sales: show an increase in this option of +7% by 2030. This is due to the indirect 
purchase of cables with EPS purchased as part of the rebound effect of unbundling. These 
are added at the net ratio of 0.21 per phone with unbundled EPS as described previously 
for the baseline. 

o  Cable – types: No changes compared to the baseline. 

95 

 
 
 
Annual sales (with Smartphones + standalone) [units] 

Stock [units] 

Figure 4.3 Measure 2 scenario evolution 2017-2030 

EPS 

Cables 

Source: Consultant own stock model calculations.  
Note: The No EPS area in the stock graph does not decline as there are no disposals assumed (unlike other EPS), the total accumulates for this reason. 

96 

 
 
 
 
 
 
Annual sales (with Smartphones + standalone) [units] 

Stock [units] 

Figure 4.4 Measure 3 scenario evolution 2017-2030 

EPS 

Cables 

Source: Consultant own stock model calculations.  
Note: The No EPS area in the stock graph does not decline as there are no disposals assumed (unlike other EPS), the total accumulates for this reason. 

97 

 
 
 
 
 
 
 
3.  SCOPE OF THE IMPACT ASSESSMENT AND ASSUMPTIONS 

During  the  inception  phase,  a  mapping  of  186  mobile  phones  and  192  other  portable  electronic 
devices was developped,161 tracking their charging characteristics and market trends. Based on the 
mapping, devices were categorised into three priority groups using the following criteria162: 

  The extent to which charging characteristics of other devices are similar to mobile phones, 
excluding  from  the  analysis  those  for  which  the  assumptions  for  mobile  phone  chargers 
could not be extrapolated; 

  The  extent  to  which  unbundling  already  exists,  de-prioritising  those  that  are  already  sold 

unbundled; 

  The trend of sales of the products, prioritising those devices with a high growth trend. 

Based on the mapping and the analysis of market data, tablets  and cameras were classified as the 
devices  with  the  highest  priority;  earbuds  and  headphones/headsets  and  hand-held  videogame 
consoles  were  classified  as  medium  priority;  and  portable  speakers,  smartwatches  and  fitness 
trackers as low priority.163  

The classification was used to prioritise the acquisition of market data for other portable devices. As 
a  result,  tablets,  cameras  and  earbuds  and  headphones  have  been  included  in  the  stock  model.164 
Impacts for other devices are assessed qualitatively. 

Given  that  other  portable  devices  have  different  charging  characteristics  to  mobile  phones  and 
varied unbundling trends, not all of the policy options are relevant for all the devices.  

Tablets 

Of all the devices analysed, tablets are the most similar device to smartphones in terms of battery 
and charging characteristics. They use similar battery charging protocols, albeit with slightly higher 
wattage – especially on those tablets that are of bigger size or that incorporate features that are more 
typical  of  laptops  (e.g.  a  keyboard).  They  also  use  the  same  types  of  connectors.  In  2019,  it  is 

161  The  sample  includes:  29  cameras  (including  action  cameras),  10  handheld  videogame  consoles,  9  e-readers,  11 
smartwatches / fitness trackers, 30 earsets and headsets, 14 laptops, 15 radio-controlled toys, 2 smartglasses, 26 portable 
speakers, 45 tablets. 
162 For more information on the prioritisation exercise conducted, see study on unbundling. 
163 Laptops and radio-controlled toys were also mapped and analysed, and excluded from further analysis. Laptops were 
excluded because they use significantly higher wattage than mobile phones, and therefore it would not be possible to 
extrapolate  data  and  assumptions  from  smartphones  to  laptops  (different  impacts  on  safety  and  the  environment). 
Radio-controlled  toys  were  excluded  because  their  charging  characteristics  also  differ  from  mobile  phones;  they 
generally  use  lower  current  (0.1-1A  vs  1-2A  used  in  mobile  phones)  and,  most  importantly,  use  different  types  of 
batteries (Ni-MH / Ni-Cd, instead of Li-Ion or Li-Polymer used in mobile phones). 
164  Data  for  Tablets  and  earsets  and  headsetswas  acquired  from  IDC;  data  for  cameras  has  been  retrieved  from 
PRODCOM and CIPA. 

98 

 
 
                                                           
estimated  that  40%  of  tablets  had  USB  micro-B  receptacles,  33%  USB  Type-C,  and  27%  had 
proprietary connectors (23% Lightning and 4% other proprietary connectors).165 All the tablets sold 
in the market nowadays are bundled with the EPS and cable. 

All  the  policy  options  could  apply  to  tablets.  Currently,  there  are  many  tablets  that  are  a  hybrid 
between  a  tablet  and  a  notebook  or  laptop,  and  therefore  the  scope  of  any  legislation  should  be 
carefully  defined.  The  impacts  of  the  policy  options  on  notebooks  and  laptops  have  not  been 
analysed. 

Digital photo cameras 

All the cameras analysed in the mapping of devices (29) have USB connectors. In some cases the 
connector is only used for data transfer (7/29), whereas in most cases it can also be used to charge 
the camera (22/29). 

There are two main types of digital cameras: cameras with built-in lenses (e.g. action cameras and 
compact cameras) and cameras with intercheangeable lenses (e.g. Reflex and mirrorless cameras). 
Cameras  with  built-in  lenses  are  normally  smaller  and  are  charged  via  USB  connectors  (USB 
micro-B  or  USB  Type-C).  Larger  cameras  (Reflex  and  mirrorless)  generally  have  removable 
(proprietary)  batteries  that  are  charged  with  external  battery  chargers.  These  chargers  are 
proprietary and do not use USB cables or connectors. Only the newest and/or premium models of 
this  type  of  cameras  have  a  USB  Type-C  receptacle  that  allows  not  only  data  transfer,  but  also 
battery charging (i.e. some of these cameras can be charged either with  a USB Type-C cable and 
EPS, or removing the battery and charging it separately using the proprietary charger). Out of the 29 
cameras analysed: 

  20 were charged via a USB connection (either USB micro-B or USB Type-C); 

  7 could only be charged by removing the battery, using the proprietary charger; 

  2  could  be  charged  either  via  USB  Type-C  charging,  or  via  the  proprietary  charger  (i.e. 

removing the battery). 

Option  1  harmonises  the  receptacles  to  USB  Type-C.  This  option  could  be  applied  to  cameras, 
adding that the receptacle should provide both data transfer and charging via USB standards. 

Cameras use significantly lower wattage than mobile phones. In the mapping of devices conducted, 
all  the  cameras  analysed  (29)  required  under  10W.  The  options  to  harmonise  battery  charging 
protocols considered in this impact assessment (measure 2) require minimum 7.5W; however, most 
cameras use less than that.  In the few cases where the cameras require  more power, the mapping 
indicates they already use USB Type-C charging. Therefore, measure 2 would not deliver the best 

165 Estimates made based upon triangulation of mapping of devices and IDC data for Tablets. 

99 

 
 
 
                                                           
technical  option  for  cameras,  as  they  would  increase  production  costs  and  retail  prices  without 
producing  any  significant  benefit  for  the  consumers  or  the  environment.  Cameras  that  allow 
charging through the USB connector may already be charged safely with EPS that use USB PD and 
USB Type-C battery charging, as they provide backwards compatibility with other USB standards. 
A voluntary option for cameras requiring over 7.5W could be explored.  

Out  of  the  29  cameras  mapped,  12  included  an  EPS  in  the  box,  9  included  an  external  battery 
charger166, and 26 included a cable. unbundling could therefore apply to cameras. 

Earbuds and headphones: Certain types of connectors used by earbuds and headphones are similar 
to the ones used in mobile phones and tablets: Lightning (48% of the units sold in the EU in 2019), 
USB  micro-B  (41%)  and  USB  Type-C  (12%).167  Common  connector,  therefore,  could  apply  to 
earbuds and headphones. Some earbuds are charged wirelessly in their box, and the box connects to 
an EPS via a USB cable. For the purpose of this study, we have treated the earbuds' box as part of 
the product, and have mapped and analysed the connector in the box. 

All  the  devices  mapped  (34)  require  less  than  10W,  and  most  require  less  than  5W.  Therefore, 
similar to the case of cameras, measure 2 is not required to charge earbuds and headphones, as this 
would increase production costs and retail prices without producing any significant benefit for the 
consumers or the environment. A voluntary option for earbuds and headphonesrequiring over 7.5W 
could be explored. 

Of the devices analysed, none of them included an EPS (hence making unbundling unnecessary for 
earbuds  and  headphones).  However,  almost  all  included  a  cable  along  with  the  hearing  device. 
Unbundling could therefore apply to hearing devices. 

Similar to  the case of tablets, earbuds  and headphones should be  carefully  defined so as to  avoid 
including hearing aids and other potential devices that are different to those referred to in this study. 

Hand-held videogame consoles 

Nine consoles were mapped, of which five used USB micro-B connectors, three used USB Type-C 
connectors,  and  one  used  a  proprietary  connector  (Sony  PS  Vita).  The  wattage  used  by  consoles 
ranged from 4W (e.g. Nintendo 2DS) to 39W (e.g. Nintendo Switch). There were two devices using 

166  The  proprietary  external  charger  to  charge  removable  batteries  is  not  considered  an  EPS.  This  type  of  charger  is 
significantly different to mobile phone EPS and therefore it is not possible to use the same assumptions in estimations 
and the stock model.  
167 Estimate made based upon triangulation of mapping of devices with IDC data for earsets and headsets. It should be 
noted that IDC only includes premium categories of earsets and headsets, as it only includes devices that are considered 
“smart”,  i.e.  include  at  least  one  of  the  following  features:  track  health/fitness;  modify  audio  beyond  blanket  noice 
cancellation;  provide  language  translation;  enable  smart  assistants.  Non  smart  earsets  and  headsetsnormally  use  USB 
micro-B receptacles. 

100 

 
 
 
                                                           
15W or more, of which one was USB PD enabled and the other used Quick Charge. All the devices 
except two (for which there was no information) were sold along with an EPS and cable. 

Harmonisation  of  connector,  and  the  unbundling  measure  could  apply  to  hand-held  videogame 
consoles.  Harmonisation  of  charging  protocol,  which  harmonise  the  use  of  battery  charging 
protocols,  may  be  applied  to  these  devices.  However,  most  devices  use  low  wattage  and 
harmonisation already exists for those using 15W or more.  

Portable speakers 

All of the 26 portable speakers mapped in the analysis used USB connectors (15 used USB micro-B 
and  11  used  USB  Type-C  connectors).  Most  of  the  speakers  required  low  wattage  (under  10W), 
although the sample included six devices accepting 15W or more. All of these used USB Type-C 
connectors and either USB Type-C or USB PD battery charging protocols. 

Given that there is  no fragmentation  of charging solutions in the market (proprietary solutions  do 
not  exist  and  USB  micro-B  connectors  are  naturally  transitioning  towards  USB  Type-C), 
harmonisation options are not strictly necesary.  

Five  out  of  26  devices  included  an  EPS  along  with  the  portable  speaker  and  all  of  the  devices 
included a cable. The unbundling measure could therefore apply to portable speakers. 

E-readers 

Most of the e-readers analysed (6 out of 8) use USB micro-B connectors and a minority (2 out of 8) 
use USB Type-C connectors. All of them are charged at 5W using the USB BC specification. As in 
the  case  of  portable  speakers,  it  is  not  proportionate  to  include  e-readers  within  the  scope  of  any 
regulatory harmonisation of connectors and charging protocol as it would not deliver any benefit to 
the  consumer  or  the  environment.  Nonetheless,  e-readers  could  of  course  also  carry  the 
interoperability labels. 

None of the devices analysed included EPS along with the e-readers, but all included a cable.  

Smartwatches and fitness trackers 

All  the  devices  analysed  are  charged  via  wireless  and/or  proprietary  connectors.  These  wearables 
are often designed to be water resistant and support hard conditions, therefore USB connectors may 
not  offer  the  best  technical  solution.  The  wattage  accepted  by  the  devices  was  below  10W  in  all 
cases. Applying the harmonisation of connector and charging protocol to smartwatches and fitness 
trackers  would  deliver  sub-optimal  charging  solutions.  Nonetheless,  those  devices  that  do  use  the 
relevant  USB  charging  technologies  could  take  part  in  the  voluntary  labelling  scheme.  However, 
given  that  wireless  is  the  most  common  charging  method  for  these  devices,  it  may  be  more 
appropriate to use the labelling scheme to communicate wireless charging protocols instead. 

Five  out  of  the  11  devices  analysed  included  an  EPS.  All  included  a  cable,  and  most  included  a 
wireless charger. Unbundling measure could be applied to mandate unbundling of EPS. With regard 

101 

 
 
 
to the cable, given that many of these devices use proprietary connectors (and USB Type-C do not 
offer the right technical option), mandating unbundling of the cable is not recommended.  

Summary of policy options for other portable electronic devices 

The table below summarises the devices for which each measure is relevant. ‘Yes’ indicates that the 
policy option could apply to that device, and the impact assessment in the remainder of this chapter 
explores  the  likely  effects  of  this;  ‘No’  indicates  that,  based  on  the  information  at  disposal,  it  is 
recommended that the policy option does not apply to the device because it is not the best technical 
option  (based  on  the  charging  characteristics  of  the  portfolio  of  devices  analysed)  and/or  the 
negative  impacts  would  clearly  overweight  the  positive  impacts;  ‘Unnecessary’  indicates  that  the 
option is feasible technically, but would not provide any benefits in relation to the baseline scenario. 

Table 4.17 - Summary of scope of measures applied 

Harmonise 
connectors 

Interoperability with common 
comm. protocol and providing 
information to consumer 

Unbundling of 
EPS 

Device 

Tablets 

Cameras 

Earbuds and headphones/headsets 

Hand-held video game consoles 

Portable speakers 

E-readers 

Smartwatches & fitness trackers 

Yes 

Yes 

Yes 

Yes 

Yes 

No 

No 

Yes 

Unnecessary 

Yes for headphones/headsets, No 
for earbuds (or other hearing 
devices) 

Yes 

Yes 

No 

No 

Yes 

Yes 

Unnecessary 

Yes 

Yes 

Unnecessary 

Yes 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

Model assumptions – other devices 

The  table  below  summarises  the  main  assumptions  that  are  built  into  the  stock  model  for  each 
policy option and other devices where data was available. It also includes the assumptions for the 
policy combination. In all policy options, the rebound effects (i.e. the percentage of consumers who 
would buy a standandalone EPS when acquiring a new unbundled phone) work in the same way as 
for smartphones. 

102 

 
 
 
EPS  –  moved  forward  transition 
to  7.5W  <=  EPS  <=27W  by  1 
year to 2024 
Cable – USB Micro-B eliminated 
the 
one  year  earlier 
baseline, in 2024 

than 

in 

EPS – same as PO1 
Cable – USB Micro-B eliminated 
one  year  earlier 
the 
baseline, in 2024 

than 

in 

(1) 
Harmonisation 
of 
end-
the 
device 
connector 

(2)  Support  of 
the 
relevant 
charging 
protocol  on  the 
end-device  and 
informing 
consumers 
about  charging 
performance 

EPS  –  all  unbundled  from  2024, 
already half in 2023 
Cables – no change 

(3) 
Making 
available on the 
market  at  least 
unbundled 
solutions 
Policy Option 1 
Policy Option 2 
Policy Option 3  EPS  –  same  as  PO2  2020-2022, 

Same as measure 1 
Same as measure 2 

same as PO4a from 2023 
Cables – same as PO2 

Policy Option 4 
Policy Option 5  EPS  –  same  as  PO1  2020-2022, 

Same as measure 1 

same as PO4a from 2023 
Cables – same as PO1 

connectors 

EPS – not relevant 
Cables – all USB Micro-B and 
Lightning 
are 
eliminated  by  2024.  Instead, 
cables  use  USB  Type-C  to  C 
connectors,  USB  Type-A  to  C 
connectors, or USB Type-C to 
Lightning connectors. 
This  policy  option  does  not 
apply to earbuds. 

already 

EPS 
– 
unbundled 
Cables – no change 

100% 

EPS – no changes 
Cables  –  USB  Micro-B  and  proprietary 
connectors  are  substituted  by  USB  Type 
C.  As  a  result,  all  cables  sold  are  either 
USB Type A to C, or USB Type-C to C. 

The option has been modelled for cameras 
(although  section  6.1  of 
report 
the 
recommends not to apply it in full). 
EPS  –  assume  share  with  proprietary 
cables  move  to  provide  EPS  and  cables 
compatible  with  USB  battery  charging 
protocols.  The  splits  between  EPS  with 
USB  Type-A  and  C  receptacles  follows 
the same split as for mobile phones.  
Cables – Eliminate USB Micro-B cables 2 
years earlier. 
EPS  –  all  unbundled  from  2024,  already 
half in 2023 
Cables – no change 

Same as measure 1 
Same as measure 2 
EPS  –  same  as  PO2  2020-
2022,  same  as  PO4a  from 
2023 
Cables – same as PO2 
Same as measure 1 
EPS  –  same  as  PO1  2020-
2022,  same  as  PO4a  from 
2023 
Cables – same as PO1 

Same as measure 1 
Same as measure 2 
EPS  –  same  as  PO2  2020-2022,  same  as 
PO4a from 2023 
Cables – same as PO2 

Same as measure 1 
EPS  –  same  as  PO1  2020-2022,  same  as 
PO4a from 2023 
Cables – same as PO1 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

4.  OTHER ASSUMPTIONS 

Model assumptions – Combination of measures and synergy effects 

The  policy  packages  are  modelled  as  the  combined  effect  of  the  individual  policy  options.  The 
underlying assumptions  for the combination of options remain the same as the measures  but  with 
the following adjustments to account for how the policy options interact with each other: 

  Policy Option 3 (measures 2 and 3): The effects of measures 2 and 3 are complementary. In 
addition,  there  is  a  synergy  effect  that  enhances  the  effectiveness  of  unbundling  (i.e.  the 
addition of measure 2 reduces the number of consumers who decide to acquire an EPS when 
they buy a phone that is unbundled). It has been assumed that the combination of measures 
in  this  package  will  reduce  the  proportion  of  consumers  who  choose  to  purchase  an  EPS 

103 

 
 
 
along with an unbundled new phone by 10%, i.e. from 57% under the baseline scenario (and 
all the measures individually) to 51%. 

  Policy Option 4 (measures 1 and 2): The impacts of this package are slightly smaller than 
the  sum  of  the  impacts  of  measures  1  and  2  individually.  This  is  because  both  of  these 
measures  entail the replacement of all remaining  USB micro-B receptacles in phones with 
USB  Type-C  receptacles,  and  therefore  this  effect  only  accrues  once  if  the  options  are 
combined. 

  Policy  Option  5  (measures  1,  2  and  3):  In  this  case,  measures  1  and  2  have  overlapping 
impacts (as explained in package 1), and measure 3 complements the effects of 1 and 2. In 
addition,  in  there  is  a  synergy  effect  similar  to  policy  option  3,  i.e.  the  proportion  of 
consumers who choose to purchase an EPS along with an unbundled new phone falls from 
57% to 51%. 

Model assumptions – Sensitivity check 

There  are  various  uncertainties  when  projecting  forward  and  assuming  market  and  technological 
developments  into the  future, and also  for the other assumptions that underpin the market  model. 
Whilst  some  assumptions  such  as  charger  profiles,  e.g.  weight,  price,  etc;  will  see  scaling  effects 
proportional to the changes made, others can have more complex effects. The model was examined 
for  variables  for  which  sensitivity  checks  would  be  possible  and  where  variance  in  the 
variable/assumption  could  have  an  important  impact  on  the  results.  Also  it  was  considered 
triangulation of data to validate model results, for example in terms of quantities of charger units, it 
provides  good  confidence  that  the  model  overall  settings  are  robust  as  the  number  of  EPS  and 
cables  in  the  stock,  compared  to  the  survey  reported  EPS  and  cables  owned  by  consumers 
correspond closely.  

One of the key sets of assumptions identified for checks was the rebound rates for EPS and cables, 
i.e.  the  proportion  of  consumers  that  would  purchase  these  standalone  in  the  case  they  were 
unbundled. In the model the rebound rates are: 

  EPS: 57% of consumers buying an EPS standalone if this  was unbundled, reduced by the 
31%  of  those  that  would  normally  have  purchased  a  standalone  EPS  in  any  case,  a  net 
rebound effect of 0.39 EPS purchased standalone for every EPS unbundled. This also has an 
indirect impact on cable purchases as 62% of standalone EPS purchases are bundled with a 
cable.  

  Cables:  a  similar  adjustment  was  made,  on  the  basis  of  75%  of  consumers  purchasing  a 
cable  standalone  if  this  was  unbundled,  reduced  by  the  41%  that  would  have  purchased  a 
standalone cable anyway, for a net effect of 0.44 cable purchases for every cable unbundled. 

Naturally, these assumptions are especially relevant for policy options 4a and 4b where unbundling 
is mandated.  

104 

 
 
 
 
Using a 35% rather than 57% assumption for consumers purchasing an EPS standalone in the case 
of unbundling results in a net effect of 0.24 EPS purchased for every EPS unbundled. Using 70% 
rather than 57% results in a net effect of 0.48. The impact of these changes is minimal on all policy 
options  except  the  ones  including  unbundling.  The  following  table  compares  these  low  and  high 
assumptions  for  unbundling  compared  to  the  central  57%  assumption  used  in  the  work.  As 
expected,  a  lower  rebound  assumption  results  in  greater  environmental  benefits  compared  to  the 
baseline  (i.e.  higher  reductions  in  emissions,  etc),  and  vice-versa  for  a  higher  assumption.  The 
overall impact of the assumption is quite significant in the results, so that if in reality the rebound 
effect is lower, then the beneficial impact of these policy options would also be higher. 

Table 4.16 - 41Results of sensitivity check of rebound effect assumption on unbundling 
PO4b average annual difference with 
baseline 
LOW 

PO4a average annual difference with 
baseline 
LOW 

CENTRAL  HIGH 

CENTRAL  HIGH 

CO2 emissions 

Material use 

E-waste 

Untreated 

Recycled 

Cost to consumers 

Benefit for manufacturers and 
wholesalers [NPV million EUR] 

-13.4% 

-9.8% 

-4.4% 

-4.1% 

-3.9% 

-0.1% 

-10.6% 

-9.0% 

-6.1% 

-2.7% 

-2.6% 

-2.3% 

4.2% 

-6.8% 

-6.6% 

-4.1% 

-1.8% 

-1.7% 

-1.4% 

6.6% 

-4.7% 

-26.2% 

-28.3% 

-12.8% 

-11.9% 

-13.6% 

-4.9% 

-19.9% 

-16.4% 

-21.8% 

-18.3% 

-10.0% 

-9.4% 

-10.7% 

2.4% 

-8.4% 

-7.9% 

-9.1% 

6.4% 

-27.4% 

-20.9% 

-17.3% 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

5. 

IMPACTS OF THE DIFFERENT MEASURES  

Following the methods in the previous two sections, the following impacts can be estimated on the different 
measures for mobile phones and for the broader scope of devices. 

Table 4.18 Summary of environmental impacts per measure for mobile phones 

Baseline 

Harmonise 
device-end 
connectors 

Support of the 
relevant protocol 
on the end-device 
and Informing 
consumers about 
charging 
performance 

Making available 
on the market at 
least unbundled 
solutions 

GHG emissions 
[ktCO2e] 

Material Use 
[tonnes] 

Cumulative 2024-2030 

7 838 

Difference with baseline 

Annual average 

1 120 

Difference with baseline 

As % 

7 963 

125 

1 138 

18 

1.6% 

7 767 

-71 

1 110 

-10 

-0.9% 

7 139 

-699 

1 020 

-100 

-8.9% 

Cumulative 2024-2030 

152 806 

155 110 

151 597 

143 710 

Difference with baseline 

Annual average 

21 829 

Difference with baseline 

2 304 

22 159 

329 

-1 209 

21 657 

-173 

-9 096 

20 530 

-1 299 

105 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As % 

e-waste [tonnes] 

Cumulative 2024-2030 
Difference with baseline 

133 196 

Annual average 

19 028 

Difference with baseline 

As % 

1.5% 

134 283 
1 088 

19 183 

155 

0.8% 

Of which Untreated 
[tonnes] 

Cumulative 2024-2030 

27 365 

27 580 

Of which Recycled 
[tonnes] 

Difference with baseline 

Annual average 

3 909 

Difference with baseline 

As % 

Cumulative 2024-2030 

70 685 

Difference with baseline 

Annual average 

10 098 

Difference with baseline 

As % 

215 

3 940 

31 

0.8% 

71 330 

645 

10 190 

92 

0.9% 

-0.8% 

132 846 
-350 

18 978 

-50 

-0.3% 

27 302 

-63 

3 900 

-9 

-0.2% 

70 556 

-129 

10 079 

-18 

-0.2% 

-6.0% 

129 650 
-3 546 

18 521 

-507 

-2.7% 

26 677 

-688 

3 811 

-98 

-2.5% 

69 087 

-1 597 

9 870 

-228 

-2.3% 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

Table 4.19: Summary of economic and social impacts for mobile phones 
Support of the 
relevant protocol 
on the end-device 
and Informing 
consumers about 
charging 
performance 

Harmonise device-
end connectors 

Baselin
e 

Making available on 
the market at least 
unbundled solutions 

Benefits to consumers (NPV million EUR) 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Competitiveness of businesses 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

45,982 

6,569 

42,143 

-3,840 

6,020 

-549 

-8.4% 

44,807 

-1,175 

6,401 

-168 

-2.6% 

48,019 

2,036 

6,860 

291 

4.4% 

Of which impact manufacturers and wholesalers (NPV million EUR) 

11 903 

1 700 

1 519 

217 

10 932 

-970 

1 562 

-139 

-8.20% 

11 682 

-221 

1 669 

-32 

-1.90% 

11 110 

-793 

1 587 

-113 

-6.70% 

Of which impact EU manufacturers (NPV million EUR) 

1 389 
-129 

198 

-18 

-8.50% 

1 471 
-48 

210 

-7 

-3.10% 

1 725 
207 

246 

30 

13.60% 

Cumulative 2024-2030 

22 177 

20 278 

21 444 

25 799 

Of which impact distributors and retailers until point of sale (NPV million EUR) 

106 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Difference with baseline 

Annual average 

3 168 

Difference with baseline 

As % 

-1 899 

2 897 

-271 

-9% 

-733 

3 063 

-105 

-3% 

 3 621 

 3 686 

517 

16% 

Other costs/impacts 

Negligible 

Negligible 

Negligible 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

Table 4.20 Summary of environmental impacts per measure for the broader scope 

Baseline 

Harmonise 
device-end 
connectors 

Support of the 
relevant protocol 
on the end-device 
and Informing 
consumers about 
charging 
performance 

Making available 
on the market at 
least unbundled 
solutions 

GHG emissions 
[ktCO2e] 

Cumulative 2024-2030 

9 052 

Difference with baseline 

Annual average 

1 293 

Difference with baseline 

As % 

9 226 

174 

1 318 

25 

1.90% 

Material Use 
[tonnes] 

Cumulative 2024-2030 

179 371 

183 033 

Difference with baseline 

Annual average 

25 624 

Difference with baseline 

As % 

e-waste [tonnes] 

Cumulative 2024-2030 

155 463 

Of which Untreated 
[tonnes] 

Of which Recycled 
[tonnes] 

Difference with baseline 

Annual average 

22 209 

Difference with baseline 

As % 

Cumulative 2024-2030 

31 914 

Difference with baseline 

Annual average 

4 559 

Difference with baseline 

As % 

Cumulative 2024-2030 

82 899 

Difference with baseline 

Annual average 

11 843 

Difference with baseline 

3 662 

26 148 

523 

2.00% 

157 419 

1 957 

22 488 

280 

1.30% 

32 301 

388 

4 614 

55 

1.20% 

84 103 

1 204 

12 015 

172 

8 995 

-57 

1 285 

-8 

-0.60% 

178 459 

-913 

25 494 

-130 

-0.50% 

155 382 

-81 

22 197 

-12 

-0.10% 

31 905 

-8 

4 558 

-1 

0.00% 

82 929 

30 

11 847 

4 

8 047 

-1 005 

1 150 

-144 

-11.10% 

165 619 

-13 752 

23 660 

-1 965 

-7.70% 

149 645 

-5 817 

21 378 

-831 

-3.70% 

30 782 

-1 132 

4 397 

-162 

-3.50% 

80 180 

-2 719 

11 454 

-388 

-3.30% 
Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

1.50% 

0.00% 

As % 

Table 4.21: Summary of economic and social impacts for the broader scope 

Baseline 

Harmonise device-
end connectors 

Support of the 
relevant protocol 

Making available on 
the market at least 

107 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
unbundled solutions 

on the end-device 
and Informing 
consumers about 
charging 
performance 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Benefits to consumers (NPV million EUR) 

49 960 

7 137 

45 619 
-4 341 

6 517 

-620 

-8.70% 

48 795 
-1 165 

6 971 

-166 

-2.30% 

52 247 
2 287 

7 464 

327 

4.60% 

Competitiveness of businesses 

Of which impact manufacturers and wholesalers (NPV million EUR) 

14 176 

2 025 

1 519 

217 

12 919 

-1 257 

1 846 

-180 

-8.89% 

13 960 

-215 

1 994 

-31 

-1.53% 

12 890 

-1 285 

1 841 

-184 

-9.09% 

Of which impact EU manufacturers (NPV million EUR) 

1 389 

-129 

198 

-18 

-8.29% 

1 471 

-48 

210 

-7 

-3.23% 

1 793 

274 

256 

39 

17.97% 

Of which impact distributors and retailers until point of sale (NPV million EUR) 

21 609 

3 087 

19 781 

-1 828 

2 826 

-261 

-8% 

20 874 

-735 

2 982 

-105 

-3% 

26 466 

4 857 

3 781 

694 

22% 

Other costs/impacts 

Negligible 

Negligible 

Negligible 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

6. 

IMPACTS OF THE AGGREGATED MEASURES  

Starting from the impacts of the single measures, it is possible to estimate the impacts of the options as in the 
four tables below. In a first assumption the costs can be estimated as the sum of the measures. In some cases, 
however, synergies are present. 

Table 4.22 Aggregated summary of environmental impacts for mobile phones 

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

GHG emissions [ktCO2e] 

Cumulative 2024-2030 

7 963 

Difference with baseline 

125 

Annual average 

1 138 

Difference with baseline 

18 

7 767 

-71 

1 110 

-10 

6 887 

-951 

984 

-136 

7 783 

-55 

1 112 

-8 

6 810 

-1 028 

973 

-147 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
As % 

1.60% 

-0.90% 

-12.10% 

-0.70% 

-13.10% 

Cumulative 2024-2030 

155 110 

151 597 

139 452 

151 831 

137 862 

Difference with baseline 

2 304 

Material Use [tonnes] 

Annual average 

22 159 

Difference with baseline 

329 

-1 209 

21 657 

-173 

-13 354 

-975 

-14 944 

19 922 

-1 908 

21 690 

-139 

19 695 

-2 135 

As % 

1.50% 

-0.80% 

-8.70% 

-0.60% 

-9.80% 

Cumulative 2024-2030 

134 283 

132 846 

128 094 

133 010 

127 549 

Difference with baseline 

1 088 

-350 

e-waste [tonnes] 

Annual average 

19 183 

18 978 

Difference with baseline 

155 

-50 

-5 102 

18 299 

-729 

-186 

19 001 

-27 

-5 647 

18 221 

-807 

As % 

0.80% 

-0.30% 

-3.80% 

-0.10% 

-4.20% 

Cumulative 2024-2030 

27 580 

27 302 

26 381 

27 335 

Difference with baseline 

215 

Of which Untreated [tonnes] 

Annual average 

3 940 

Difference with baseline 

31 

-63 

3 900 

-9 

-985 

3 769 

-141 

-30 

3 905 

-4 

26 277 

-1 088 

3 754 

-155 

As % 

0.80% 

-0.20% 

-3.60% 

-0.10% 

-4.00% 

Cumulative 2024-2030 

71 330 

70 556 

Difference with baseline 

645 

-129 

Of which Recycled [tonnes] 

Annual average 

10 190 

10 079 

Difference with baseline 

92 

-18 

68 325 

-2 359 

9 761 

-337 

70 645 

-40 

10 092 

-6 

68 005 

-2 680 

9 715 

-383 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

As % 

0.90% 

-0.20% 

-3.30% 

-0.10% 

-3.80% 

Table 4.23 Aggregated summary of economic and social impacts for mobile phones 
Option 4 

Option 3 

Option 1 

Option 2 

Benefits to consumers (NPV million EUR) 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

42 143 

-3 840 

6 020 

-549 

-8.40% 

44 807 

-1 175 

6 401 

-168 

-2.60% 

45 966 

-16 

6 567 

-2 

0.00% 

40 944 

-5 038 

5 849 

-720 

-11.00% 

Competitiveness of businesses 

Option 5 

44 505 

-1 478 

6 358 

-211 

-3.20% 

Of which impact manufacturers and wholesalers (NPV million EUR) 

Cumulative 2024-2030 

10 932 

11 682 

Difference with baseline 

Annual average 

Difference with baseline 

-970 

1 562 

-139 

-221 

1 669 

-32 

As % 

-8.20% 

-1.90% 

10 725 

-1 178 

1 532 

-168 

-9.90% 

10 693 

-1 210 

1 528 

-173 

10 216 

-1 686 

1 459 

-241 

-10.20% 

-14.20% 

Of which impact EU manufacturers (NPV million EUR) 

Cumulative 2024-2030 

1 389 

1 471 

1 642 

1 342 

1 608 

109 

 
 
 
 
 
 
 
 
 
 
 
Difference with baseline 

Annual average 

Difference with baseline 

-129 

198 

-18 

-48 

210 

-7 

123 

235 

18 

-176 

192 

-25 

89 

230 

13 

As % 

-8.50% 

-3.10% 

8.10% 

-11.60% 

5.90% 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Of which impact distributors and retailer until point of sale (NPV million EUR) 

20 278 

-1 899 

2 897 

-271 

-9% 

21 444 

-733 

3 063 

-105 

-3% 

24 517 

2 339 

3 502 

334 

10.5% 

19 559 

-2 618 

2 794 

-374 

-11.8% 

24 072 

1 895 

3 439 

271 

8.5% 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

Table 4.24 Aggregated summary of environmental impacts for broader scope of devices 

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

Cumulative 2024-2030 

9 226 

Difference with baseline 

174 

GHG emissions [ktCO2e] 

Annual average 

1 318 

Difference with baseline 

25 

8 995 

-57 

1 285 

-8 

7 799 

-1 253 

1 114 

-179 

9 046 

-6 

1 292 

-1 

7 767 

-1 286 

1 110 

-184 

As % 

1.93% 

-0.60% 

-13.80% 

-0.10% 

-14.20% 

Cumulative 2024-2030 

183 033 

178 459 

161 409 

179 754 

161 130 

Difference with baseline 

3662 

-913 

-17 962 

383 

-18 242 

Material Use [tonnes] 

Annual average 

26 148 

25 494 

Difference with baseline 

524 

-130 

23 058 

-2 566 

25 679 

55 

23 019 

-2 606 

As % 

2.04% 

-0.50% 

-10.00% 

0.20% 

-10.20% 

Cumulative 2024-2030 

157 420 

155 382 

148 127 

156 146 

148 604 

Difference with baseline 

1957 

-81 

e-waste [tonnes] 

Annual average 

22 489 

22 197 

Difference with baseline 

280 

-12 

-7 336 

21 161 

-1 048 

As % 

1.26% 

-0.10% 

-4.70% 

Cumulative 2024-2030 

32 302 

31 905 

Difference with baseline 

388 

-8 

Of which Untreated [tonnes] 

Annual average 

4 615 

4 558 

Difference with baseline 

56 

As % 

1.22% 

Cumulative 2024-2030 

84 103 

Difference with baseline 

1204 

-1 

0.00% 

82 929 

30 

Of which Recycled [tonnes] 

Annual average 

12 015 

11 847 

Difference with baseline 

172 

4 

30 493 

-1 421 

4 356 

-203 

-4.50% 

79 437 

-3 462 

11 348 

-495 

683 

22 307 

98 

0.40% 

32 056 

143 

4 579 

20 

0.40% 

83 418 

519 

11 917 

74 

-6 859 

21 229 

-980 

-4.40% 

30 594 

-1 320 

4 371 

-189 

-4.10% 

79 750 

-3 149 

11 393 

-450 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

As % 

1.45% 

0.00% 

-4.20% 

0.60% 

-3.80% 

110 

 
 
 
 
 
 
Table 4.25 Aggregated summary of economic and social impacts for broader scope of devices 

Option 1 

Option 2 

Option 3 

Option 4 

Option 5 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

Benefits to consumers (NPV million EUR) 

45 619 

-4 341 

6 517 

-620 

-8.69% 

48 795 

-1 165 

6 971 

-166 

-2.30% 

50 202 

242 

7 172 

35 

0.50% 

44 421 

-5 540 

6 346 

-791 

-11.10% 

48 236 

-1 724 

6 891 

-246 

-3.50% 

Competitiveness of businesses 

Of which impact manufacturers and wholesalers (NPV million EUR) 

12 919 

-1 257 

1 846 

-179 

-8.86% 

1 390 

-129 

199 

-18 

13 960 

-215 

1 994 

-31 

12 507 

-1 669 

1 787 

-238 

12 679 

-1 497 

1 811 

-214 

11 713 

-2 463 

1 673 

-352 

-1.53% 

-11.80% 

-10.60% 

-17.40% 

Of which impact EU producers: (NPV million EUR) 

1 471 

1 710 

-48 

210 

-7 

191 

244 

27 

1 342 

-176 

192 

-25 

1 675 

156 

239 

22 

As % 

-8.49% 

-3.23% 

12.60% 

-11.60% 

10.30% 

Cumulative 2024-2030 

Difference with baseline 

Annual average 

Difference with baseline 

As % 

Of which impact distributors and retailers until point of sale (NPV million EUR) 

19 781 

-1 828 

2 826 

-261 

-8% 

20 874 

-735 

2 982 

-105 

-3% 

25 189 

3 580 

3 598 

511 

16.6% 

19 062 

-2 546 

2 723 

-364 

-11.8% 

24 811 

3 202 

3 544 

457 

14.8% 

Source: Impact assessment study on Unbundling of mobile phones and similar electronic devices (2021) 

111 

 
 
 
 
 
 
 
 
 
 
 
ANNEX 5: STATE-OF-PLAY OF CHARGING TECHNOLOGIES 

This section provides an overview of the chargers for mobile phones and the main features 
that influence interoperability, including the main components of chargers, and the status 
of fast and wireless charging.  

A charging solution is formed by three main elements:  

1.  The External Power Supply (EPS)  

This  is  the  device  that  is  typically  plugged  into  the  sockets  at  home,  which  are 
connected to the electrical wiring and, in turn, to the electric grid. It typically has a 
USB type A or USB type C interface so to allow cables to be connected to it, for 
the purposes of charging the devices. 

2.  A  cable  assembly  allowing  power  transfer  from  the  EPS  to  the  device.  At  the 
termination that goes into the EPS, cables mirror the relevant interface of the EPS 
(i.e. USB type A or USB type C). 

a.  For wired charging solutions at the mobile end, cables can have a USB type 
C,  a  micro  USB  type  B  or  a  proprietary  interface.  In  the  past,  and  still 
occasionally today, they could not be detachable, i.e. the end that goes into 
the EPS is fused with the EPS itself. 

b.  For  wireless  charging  solutions,  the  cable  terminates  with,  or  can  be 

connected to, a pad which allows wireless charging. 

For the purposes of this Impact Assessment, the combination of an EPS as in point 
1 and a cable as in point 2a is intended to be a “charger”. The combination of an 
EPS as in point 1 and a pad as in point 2b is intended to be a “wireless charger”. 

3.  The device’s battery 

This  is  a  part  of  the  device,  which  has  an  appropriate  interface  (and  internal 
circuitry) to receive the power from the charger. 

For a device to  charge, these three elements need to be interoperable and the EPS has to 
provide  an  appropriate  level  of  electric  current  (or  voltage)  that  the  battery  needs.  In  the 
last years, most of chargers have become able to support different levels of electric current 
(or voltage), so it is frequent that the charger and the mobile phone communicate through a 
specific protocol to establish the best charging profile that both can support. 

The following sections 1, 2 and 3 describe, respectively, points 1 and 2a and 2b above in 
more detail. 

1.  The EPS 

112 

 
After the first MoU, EPS were typically providing 7.5W (5V at 1.5A). With the increase of 
the  dimension  of  the  phones,  bigger  batteries  with  higher  capacities  were  placed  on  the 
market.  These  requested  EPS  to  delivery  of  increased  power  levels  to  keep  the  charging 
speed at least in line with the old new technologies. The USB Implementers Forum (USB-
IF)168,  formed  by  100+  members  developed  in  cooperation  with  IEC  the  standard  series 
62680. This standard series set the specifications for USB Power Delivery and USB Type-
C. The USB Power Delivery (PD) specification describes the architecture and protocols to 
connect the battery charger and the device to be charged (e.g. a mobile phone). During this 
communication, the optimum charging voltage and current are determined to deliver power 
up  to  100W  through  the  USB  connector.  Some  mobile  phone  manufacturers  have  since 
incorporated  USB  PD  in  their  devices.  On  8  January  2018,  USB-IF  announced  the 
"Certified USB Fast Charger" which certifies chargers that use the feature “Programmable 
Power Supply” (PPS) of the USB PD specification. The interoperability of the “USB PD 
family”  is  defined  by  the  standard  EN  63002,  which  allows  the  device  and  EPS  to 
communicate  with  each  other,  so  that  the  EPS  provides  only  the  power  that  the  device 
requires,  avoiding  damaging 
the  battery  and  maximising  performance.  Specific 
manufacturers developed specific technology, e.g. Qualcomm’s Quick Charge, which are 
nevertheless compatible with the USB PD. 

In  summary,  EPS  today  can  be  classified  into  four  main  typologies,  as  described  in  the 
table below.  

Interoperability 
with low-end and 
old phones 

Interoperability 
with high end 
phones 

Yes 

Yes 

Can charge high-
end phones at a 
normal speed 

Yes 

Yes, although safety 
(for user and device) 
is not guaranteed 

Only phones 
including Quick 
Charge 

Yes 

Yes 

Table 5.1: Typology of EPS for mobile phones  

Type of EPS 

Specifications applicable 

Common 
EPS, as 
defined in 
2009 MoU 

USB PD 

Quick 
Charge v1, 
v2, v3 
Quick 
Charge v4, 
v4+ 

IEC 62684 

EN 62680-1-2 
EN 62680-1-3 
EN 63002 

None 

Programmable Power Supply 
Compatible with USB PD and 
USB C specifications 

Source: Commission’s contractor 

168 https://www.usb.org/  

113 

 
                                                           
As regard the interfaces on the EPS, the following applies: 

Table 5.2: Maximum power and speed for data transfer supported by USB connectors – EPS side 

Type of 
connector 

Latest specification it 
supports (power) 

USB PD (EN 62680-2) 

Latest specification it 
supports (data 
transfer) 
USB 3.2 

Max Power 

Max data 
transfer 

100W 

20 Gbps 

USB PD (EN 62680-2) 

USB 4 

100W 

40 Gbps 

USB Type-
A 
USB Type-
C 

When consulted for this study, phone manufacturers were asked about compliance of their 
products  (mobile  phones  and  chargers  included  in  the  box)  with  these  standards.  All 
manufacturers confirmed that their chargers and mobile phones with charging capacity of 
up to 5W comply with 62684. Only two companies provided information on devices using 
more  than  5W.  In  one  case,  all  devices  are  compliant  with  IEC  62680  series  and  IEC 
63002, whereas in another case there is a mix of devices compliant with 62680 series and 
63002, and devices with proprietary fast charging solutions.  

The  study  team  conducted  a  review  of  phones  available  in  the  market  in  2018.  The 
contractor  estimated that in  2018, 71% of phones sold  in  the EU included an EPS in  the 
box  that  is  compatible  with  IEC  62684,  11%  included  an  EPS  compliant  with  USB  PD 
specifications, and 18% included an EPS using a proprietary solution. Among the latter, it 
should be noted that some proprietary solutions (Quick Charge v4 and v4+) are compatible 
with  USB  PD  and  USB  Type-C  specifications,  and  therefore  interoperable  with  other 
devices. The contractor also estimated that a large proportion of these devices incorporated 
the latest Quick Charge solutions (v4 and v4+). 

2.  The cable, in the case of wired charger 

The  cable  assembly  is  another  element  that  determines  interoperability.  When  the  first 
MoU  was  signed  in  2009,  signatories  committed  to  use  USB  micro-B  connectors  at  the 
phone end. The MoU, however, also allowed the use of proprietary connectors. The shape 
of the connector at the EPS end was not directly covered by the 2009 MoU. However, the 
standard  that  defined  “the  common  charger”  (EN  62684)  indicated  that  EPS  need  to  be 
“provided  with  a  detachable  cable  and  equipped  with  a  USB  Standard  A  receptacle  to 
connect to the EPS”.  

To  date,  the  majority,  if  not  all,  of  mobile  phone  manufacturers  complied  with  the 
requirement of providing an EPS with  a detachable cable and USB A sockets  and plugs. 
Similarly, most mobile phone manufacturers adopted USB micro-B at the phone end, and 
this has been the mainstream solution until the irruption of USB Type-C. USB Type-C is a 
24-pin  USB  connector  system,  which  is  distinguished  by  its  two-fold  rotationally-
symmetrical  connector.  The  specification  was  finalised  in  2014,  and  published  shortly 

114 

 
 
after.  The  EN  62680-1-3  sets  specifications  for  connectors,  cables,  adapters,  supporting 
charge  of  up  to  15W.  However,  it  can  also  support  USB  PD  (up  to  100W).  Since  then, 
USB  C  has  started  to  gradually  replace  USB  micro-B  as  the  connector  of  choice  at  the 
device end (starting in higher-end phones).  

The exception is one manufacturer with  an approximate market share in the last  years of 
20%, who has kept a proprietary interface at the mobile end, but includes USB Type-C in 
other  products,  e.g.  laptops.  According  to  this  manufacturers,  an  important  difference  is 
that the proprietary interface occupies less space inside the phone than the USB Type-C.  

3.  The assembly for wireless charging 

Wireless charging is an incipient technology to charge portable devices. It requires a pad 
which can be connected directly to the EPS or through a cable ending with a USB Type C 
interface.  Compared  to  the  energy  transfer  of  a  wired  charger,  its  energy  efficiency  is 
around 60%169.  

The  physical  operation  principle  refers  to  the  way  in  which  the  transmitter  sends  energy 
into the receiver (or coupling). The following technologies can be differentiated based on 
that criteria: 

  Inductive  coupling.  Inductive  coupling  uses  induction  as  a  transmission  method. 
Basically  the  transmitter  coil,  through  which  high  frequency  AC  current  flows, 
generates a changing magnetic flux that induces then a current in the receiver coil, 
if put close enough. This placing becomes a crucial factor for inductive  coupling, 
since  its  frequency  level  only  allows  proper  power  transfer  in  very  close  ranges 
(few millimetres). 

  Magnetic  resonance  coupling.  Magnetic  resonance  is  based  in  RLC  circuits  in 
which  current  is  fed,  causing  the  capacitor  and  inductor  to  exchange  energy 
periodically  (Développement,  Yole,  2018).  When  working  at  resonant  frequency, 
the amount of energy stored increases with time, escalating the voltage and current 
level  in  the  transmitter  and  thus  generating  a  more  powerful  magnetic  field, 
allowing looser coupling than the inductive method. 

  Capacitive coupling. Capacitive coupling uses capacitors (or induced capacitance 
between circuits) to transmit energy through an electric field. Since it requires large 
areas it is not used in electronics charging applications (Lu, Wang, Niyato, In Kim, 
& Han, 2016). 

  RF radiation. This technique uses diffuse RF/microwave radiation in order to send 
energy (Lu, Wang, Niyato, In Kim, & Han, 2016). It works in very high frequency 

169 https://data.europa.eu/doi/10.2873/537546  

115 

 
                                                           
ranges  and  can  transmit  energy  to  a  distance  up  to  kilometres,  although  it  is  not 
widely used due to safety reasons. 

  Distributed laser charging. Another emergent technology identified is distributed 
laser  charging,  which  could  potentially  impact  the  wireless  charging  landscape 
greatly  (Liu,  et  al.,  2016).  This  technology  is  based  energy  transmission  through 
photons  than  are  then  re-converted  to  electricity  through  a  small  PV  panel  in  the 
receiver. This technology could offer free positioning and long distance charging to 
several  devices  simultaneously  as  well  as  further  safety,  since  charging  is 
automatically  stopped  when  an  object  is  placed  in  the  line  of  sight  of  the  device 
being  charged  (Zhang,  Pang,  Georgiadis,  &  Cecati,  2019).  The  main  limitations 
currently seem to be the low efficiency and power output of these systems, being in 
the  range  of  around  20%  and  5-10  W  respectively.  This  does  however  place  this 
emergent  method  in  the  same  application  range  of  current  wireless  charging 
technologies (i.e. mobile phones and other small electronic devices). 

  Acoustic  energy  transfer  (AET).  Another  existing  wireless  energy  transmission 
method is acoustic energy transfer (AET). As the name suggests, electric energy is 
transmitted in form of sound (i.e. mechanical vibration). As explained in (Awal et 
al.,  2016),  AET  systems  usually  consist  on  a  transmitting  side  which  converts 
electricity in vibration, a medium area (which can be any solid, liquid or air) and a 
receiver  consisting  mainly  in  a  transducer  converting  vibration  back  to  electric 
pulses. AET’s main advantages compared to the aforementioned means of energy 
transfer are its safety  (as no electromagnetic wave  or laser is  being used) and it’s 
friendliness  to  otherwise  problematic  transfer  mediums  like  metals.  Its  main 
potential  applications  according  to  (Awal  et  al.,  2016)  would  be  mainly  through 
wall  and  in-body  power  transfer.  The  earlier  has  actually  been  devoted  the  most 
attention to, with reported peaks of 1 kW power transfer at around 88% conversion 
efficiency.  Over-the-air  energy 
to  be  rather 
challenging  for  AET,  with  a  handful  of  tests  having  been  made  using  ultrasonic 
transducers. With those, the maximum power rate achieved was in the level of 𝜇W. 
It  is  therefore,  highly  unlikely  that  this  technology  will  be  seen  in  consumer 
electronic charging anytime soon. 

transmission  seems  however 

The first three technologies are also known as near field technologies because they transfer 
power over short distance, while the  rest  are  far  field  technologies.  It  is  also  to  be noted 
that  in  general;  inductive,  resonant  and  Radio  Frequency  technologies  work  over  similar 
principles but at different frequencies, which in turn affects the charging distance and the 
interoperability between the systems. The rest do use different physical means to transmit 
energy. Although all these ways of transferring energy are well known, their application to 
powering electronic devices is fairly recent (even in its infancy for many of them). 

In this Impact Assessment high power Wireless Power Transfer (e.g. for charging electric 
vehicles) is not considered, as the related equipment is out of scope of the initiative.  

116 

 
There are three main technologies for wireless charging portable electronics of interest of 
this initiative: Airfuel, Qi and PMA, which are all being developed by consortia of major 
market  players.  Qi  and  PMA  seem  to  have  been  the  preferred  technologies  by  mobile 
manufacturers to date. Most smartphones use the Qi technology, although some devices are 
also  compatible  with  PMA.  Qi  was  released  in  2008,  and  by  February  2019  there  were 
over  220  devices  which  had  Qi  built-in170.  Wireless  chargers  only  work  with  compatible 
devices. Specific standards reflect the specifications of these technologies, e.g. EN 63028 
(AirFuel  Wireless  Power  Transfer  System  Baseline  System  Specification)  and  IEC  PAS 
63095 (The Qi wireless power transfer system power class 0 specification).  

Interoperability of the External Power Supply (EPS) 

Traditionally, the EPS sold  to  charge mobile phones and other portable devices followed 
the  standard  IEC  62684,  published  in  2011  and  updated  in  2018.  This  standard  specifies 
the  interoperability  of  common  EPS  for  use  with  data-enabled  mobile  telephones.  It 
defines the common charging capability and specifies interface requirements for the EPS. 
The  maximum  power  allowed  by  this  standard  is  7.5W  (5V  at  1.5A).  This  standard 
nowadays would be insufficient to power certain devices (e.g. high-end mobile phones and 
tablets) or would charge them at a very low speed. 

Since then, new technologies using higher current and/or voltage have emerged. Table 5.3 
offers  a  summary  of  standard  solutions,  and  Table  5.4  of  proprietary  charging  solutions. 
Battery charging protocols are discussed more in depth in sections 4.1.1 and 4.2.2. 

Table 5.3: Standard battery charging protocols 

Charging 
technology 

Common EPS, 
as defined in 
2009 MoU172 

USB Battery 
Charging 1.2 

Battery 
charging 
specifications 
applicable 

IEC 62684 

EN-IEC 
62680-1-1 

Applicable 
interface171 

USB Standard-
A (source), 
USB Micro-B 
(sink), USB 
Type-C 
(source or 
sink) 

Voltage 

Current 

Power 

5V 

Up to 1.5A 

Up to 
7.5W 

170 Source: https://qi-wireless-charging.net/qi-enabled-phones/  
171 Source refers to the EPS, and sink to the device that is charged. It should be noted that devices can be both 
source and sink (e.g. when a laptop is charged it would be a sink, and when it is used to charge other devices 
it would be a source). 
172  Following  the  MoU  signed  in  2009,  CENELEC  received  a  mandate  from  the  European  Commission  to 
develop  a  harmonised  standard  for  mobile  phone  chargers.  In  response,  CENELEC  created  a  task  force  to 
develop  the  interoperability  specifications  of  a  common  EPS,  and  work  was  transferred  into  the  IEC.  The 
IEC published the standard IEC 62684 in 2011 and updated it in 2018. 

117 

 
 
                                                           
USB Type-C 

EN-IEC 
62680-1-3 

USB PD 2.0 
(superseded) 

EN-IEC 
62680-1-2 

USB PD 3.0 

EN-IEC 
62680-1-2 

USB PD 3.0 + 
PPS 
(Programmable 
Power Supply) 

EN-IEC 
62680-1-2 

Source: Commission’s contractor 

USB Type-C 
(source or 
sink) 
USB Standard-
A (source), 
USB Type-C 
(source or 
sink) 
USB Type-C 
(source or 
sink) 

USB Type-C 
(source or 
sink) 

5V 

1.5A, 3A 

7.5W or 
15W 

5V, 9V, 15V, 20V 

Configurable 
up to 5A173 

Up to 
100W174 

5V, 9V, 15V, 20V 

Configurable 
up to 5A 

Up to 
100W 

5V Prog, 9V Prog, 
15V Prog and 
20V. PPS adds 3V 
to 21 V in 20mV 
increments 

Configurable 
up to 5A 

Up to 
100W 

Table 5.4: Main proprietary battery charging protocols175 

Charging 
technology 

Quick Charge 
1.0 

Quick Charge 
2.0 

Quick Charge 
3.0 

Battery 
charging 
specifications 
applicable 

None 

None 

None 

Interface 

Voltage 

Current  Power 

USB Standard-A 
(source), USB 
Micro-B (sink) 
USB Standard-A 
(source), USB 
Micro-B (sink) 
USB Standard-A 
(source), USB 
Micro-B (sink), 
USB Type-C (sink) 

5V 

2A 

10W 

5V, 9V, 12V 

3A 

18W 

3.6-20V 
(200mV 
increments) 

3.6-20V 
(200mV 
increments) 

2.5A, 
4.6A 

2.5A, 
4.6A 

18W 

100W 

None (QC mode) 

Quick Charge 
4 and 4+ 

USB Type-C 
(source or sink) 

USB PD mode 

5V, 9V 

3A 

27W 

173 Power transfer over 3A requires use of an electronically marked 5A cable 
174 Power over 60W requires the use of USB Type-C at the source 
175 Only proprietary charging protocols that are relevant for the EU market are listed. The table does not aim 
to be comprehensive of all existing proprietary charging protocols. 

118 

 
                                                           
USB PD 3.0 PPS 
mode 

Quick Charge 
5 

N/A 

USB Type-C 
(source or sink) 

Huawei 
SuperCharge 

None 

USB Standard-A 
(source), USB 
Type-C (sink) 

3 V - 21 V (20 
mV steps 
increments) 

3A 

27W 

N/A 

N/A 

+100W 

10V, 5V, 4.5V 

10V, 5V, 20V 

2.25A, 
4.5A, 5A 

4A, 8A, 
3.25A 

20W 

40W 

11V 

6A 

66W 

None 

VOOC 

20W 
USB Standard-A 
25W 
(source), USB 
50W 
Type-C (sink), 
USB micro-B 
30W 
(sink) 
65W 
Source:  Ipsos  MORI,  based  on  multiple  sources:  literature  review  (e.g.  technical  standards  and 
other  technical  documentation),  interviews  with  manufacturers,  mapping  of  portable  electronic 
devices. 

4A 
5A 
5A 
6A 
6.5A 

5V 
5V 
10V 
5V 
10V 

Standard charging solutions for EPS 

Evolution of USB charging protocols 

Universal Serial Bus (USB) is a set of specifications developed for serial data transmission 
by  the  USB  Implementers  Forum  (USB-IF).  The  objective  of  the  first  specification 
developed,  USB  1.0,  was  to  allow  an  easy  and  high  speed  connection  between  PC  and 
peripherals. The speed of data transmission of USB 1.0 was between 1.5 and 12 Mbits/s, 
the voltage was 5V, and the maximum current was 100 mA (0.5 W). Several connectors’ 
shapes were adopted to implement this protocol.  

USB 2.0 was released in 2001, increasing the speed of data transmission to  480 Mbits/s, 
and the current to 500mA (2.5W). USB 3.0, released in 2008, increased the data transfer 
rate  to  5  Gbits/s  and  the  current  to  0.9  A  (delivering  up  to  4.5W  of  power).  These 
protocols,  however,  were  not  oriented  to  charging  devices,  and  interoperability  was  not 
guaranteed  as  there  were  no  clear  specifications  or  standards  for  USB-based  charging 
products. 

In order to facilitate interoperability, the USB-IF created a specification for battery charge 
and/or  power  delivery:  “Battery  Charging  Specification  –  BC  1.0,  BC  1.1,  and  BC  1.2”, 
released in 2007, 2009 and 2010, respectively (IEC 62680-1-1). The latest revision of BC 
1.2 was published in 2015. The power flow of the USB BC is unidirectional, from the EPS 
to  the  connected  device,  and  limited  to  7.5W.  This  protocol  has  a  wider  scope  than  IEC 
62684, which is specific to mobile phones. 

119 

 
 
USB Type-C is  a standard designed to  increment the amount of power  flowing  from  the 
the  EPS  to  the  device,  hencereducing  duration  of  the  charge.  The  standard  extended  the 
power capabilities to 15 W, with current being dinamically managed in the interval of 0.5A 
to  3A.  The  connectors  are  symetric  and  reversable.  With  this  standard,  data  transmision 
speed was also increased to 10 Gbits 

USB Power Delivery 1.0, released in 2012, allowed power delivery of up to 100W over a 
single  USB.  In  2014  an  updated  version,  USB  PD  2.0,  was  released  together  with  the 
specification for the USB Type-C connector (IEC 62680-1-3). In 2015, a third version of 
the protocol, USB PD 3.0, was published (reviewed in 2019). The protocol defines all the 
elements of a USB system: hosts, devices, hubs, chargers and cable assemblies, as well as 
the architecture, protocols, power supply behaviour, connectors and cabling required when 
using USB PD. 

USB PD 2.0 can be used with USB Type-A, Type-B and Type-C connectors. USB PD 3.0, 
however, can only be used with USB Type-C connectors. 

USB Type-C main characteristics are: 

  Power delivery up to 100W. 

  Symmetry (it can connect both the EPS and the device).  

  Simultaneous data transmission and power delivery. 

USB Power Delivery (USB PD) 

The Universal Serial Bus Power Delivery (USB PD) is a technical specification (EN-IEC 
62680-1-2)  that,  combined  with  a  Type-C  connector  (EN-IEC  62680-1-3),  allows  an 
increment of the power that can be delivered to electrical devices. 

USB  PD  can  be  divided  into  physical  and  protocol  layers.  The  physical  layer  (i.e.  the 
hardware) is composed by the EPS, the cable or cord with a USB Type-C connector and 
the  downstream  unit.  The  protocol  layer  (i.e.  the  software)  defines  the  communication 
protocol and the content of the communication. Devoted chips (SoC), USB compliant, are 
required for the implementation of the communication protocol. 

Downstream  devices  can  be  divided  into  those  that  can  store  energy,  such  as  mobile 
phones, tablets, or laptops; and those that cannot store energy, such as desktop computers, 
docking stations and monitors. 

Figure 5.1. Characteristics of the USB PD 

120 

 
The  power  transmission  can  be  implemented  in  two  different  modes,  following  the 
standard IEC 62680-1-2: 

  Fixed Supply Operation. The EPS identifies a set of fixed voltages (5 V, 9 V, 15 V 

and 20 V) and current (maximum of 5 A). 

  Programmable Power Supply Operation (PPS). The voltage and the current can be 
individually  controlled.  The  voltage  varies  between  3.3V  and  21  V  while  the 
current can increase up to 5 A. This power topology allows a better control of the 
thermal rise of the battery during a high power charge.  

How does the EPS “know” how much power it should deliver? 

When  an  EPS  and  a  downstream  device  are  connected,  they  exchange  information.  The 
standard  IEC  62680-1-2  states  that  USB  PD  compliant  EPS  shall  be  able  to  charge  non-
compliant  devices.  During  the  smart  talk,  or  handshake,  the  EPS  identifies  if  the  device 
downstream  is  a  USB  PD  type  and  determines  whether  it  should  apply  fast,  or  regular 
(overcurrent, 
charge. 
overtemperature, overvoltage, etc.) during information exchange. 

information  about  device  protections 

It  also  provides 

The standard also defines five basic power levels and requires that each power level shall 
be able to deliver previous lower levels. This means that if an EPS can deliver up to 100W 
(20V/5A), it should also be able to safely charge other devices that require less power (e.g. 
27W or 15W). 

USB PD Certification 

121 

EPS-Portable AC/DC adapterDockingstationSmartphone, TabletsLi-ionBatteryPC /  LaptopLi-ionBatteryChip ontheEPS sideChip ontheDevicesideInterchangeof information“handshakingprotocol”Cable withTypeC connectoronbothsides 
 
On 8 January 2018, USB-IF announced the "Certified USB Fast Charger" which certifies 
chargers  that  use  the  feature  "Programmable  Power  Supply"  (PPS)  of  the  USB  PD 
specification.  The  certification  allows  manufacturers  to  use  the  USB-IF  logo  in  their 
products, which are also included in the USB-IF website176. 

According to interviewees, many manufacturers decide not to certify their products, even if 
they  are  compliant  with  the  USB  PD  specification,  due  to  a  variety  of  reasons,  e.g.: 
certification costs, administrative burden, low perception of advantages of certification, or 
the need to test the products in external laboratories (which can give rise to concerns about 
IP leakage). 

On  the  other  hand,  products  that  include  add-ons  beyond  USB  PD  (e.g.  EPS  providing 
power  via  USB  PD  or  a  proprietary  solution,  depending  on  the  device  that  the  user 
connects) cannot be certified. 

Proprietary charging solutions for EPS 

In the smartphone ecosystem, many models use in-house technologies rather than the more 
ubiquitous USB PD standard or Quick Charge. However, only a few of these technologies 
are truly proprietary. Many are just USB PD or Quick Charge repackaged under a different 
brand name, such as MediaTek’s PumpExpress, which uses USB PD. 

This  sub-section  explores  the  main  fast  charging  technologies  that  are  truly  proprietary: 
Qualcomm’s Quick Charge, Huawei SuperCharge, and Oppo VOOC. 

Quick Charge 

Quick  Charge  (QC)  is  a  proprietary  Qualcomm  battery  charging  protocol  used  for 
managing power delivered over USB cables and connectors, mainly by communicating to 
the EPS and negotiating a voltage. QC is  an optional feature available with Qualcomm’s 
Snapdragon SoC.  

The first fast charging technology available on the market was Qualcomm’s Quick Charge 
1.0, released in 2013 and providing up to 10W. In 2014, Qualcomm released Quick Charge 
2.0, which provided maximum power of 18W. 

Quick Charge 3.0, released in 2016, introduced the feature INOV (Intelligent Negotiation 
for  Optimum  Voltage),  which  allowed  for  a  fined  tuned  power  output  and  a  more 
optimized charging cycle. Instead of providing a fixed voltage, Quick Charge 3.0’s INOV 
communicated  with  the  device  to  request  any  voltage  between  3.2V  and  20V  at  200mV 
increments, allowing for a wider selection of voltages.  

176 The USB-IF website (https://www.usb.org/products) includes a list of products that have passed the USB-
IF compliance programme. 

122 

 
                                                           
INOV is able to dynamically adjust the charging voltage over the battery charging cycle. 
As a battery charges up, it slowly draws less and less current, slowing down the charging 
speed.  Qualcomm  stated  that  INOV  allows  the  phone  to  request  just  enough  voltage  to 
reach the desired charge current, thereby maximising efficiency. 

Quick  Charge  4  was  announced  in  December  2016  alongside  the  Snapdragon  835  SoC. 
Quick  Charge  4  introduces  two  charging  modes:  QC  and  USB  PD.  This  means  that  the 
device would charge with USB PD if either the device or the EPS are not QC compatible. 
It also featured additional safety measures to protect against over-voltage, over-current and 
overheating, as well as cable quality detection. QC 4.0 was not compatible with previous 
QC versions. Qualcomm announced Quick Charge 4+ in 2017, including some additional 
safety features, as well as compatibility with QC 2.0 and QC 3.0 devices. 

Quick  Charge  5  was  announced  in  July  2020.  Qualcomm  states  that  this  standard  is 
compatible  with  USB  PD  PPS  (although  it  could  not  be  certified  as  it  includes  add-ons 
beyond USB PD).  

Quick Charge comes as an option with Snapdragon SoC and it has been adopted by a large 
number  of  mobile  phone  manufacturers,  such  as  Samsung,  BQ,  Lenovo,  LG,  Redmi, 
Xiaomi, HTC, Nokia, or Sony. As of November 2020, no devices featured QC 5 yet.177 It 
should  be  noted  that  not  all  devices  that  include  Snapdragon  SoC  use  QC.  For  instance, 
Google Pixel phones use Snapdragon chips, but their battery charging protocol is USB PD. 
Other manufacturers that were early adopters of Quick Charge, such as Samsung, continue 
using Snapdragon chips but have moved to USB PD. 

According to interviewees, QC has also been adopted by manufacturers of other devices, 
including tablets, drones, wireless speakers, powerbanks, and mobile 4G routers. EPS that 
use QC bring USB Type-A or USB Type-C sockets, or both if they are multi-port. 

Huawei SuperCharge 

Huawei,  through  its  affiliated  company  HiSilicon,  produces  their  own  SoC,  known  as 
Kirin. This SoC incorporates Huawei's proprietary charging solution, SuperCharge. There 
are  two  main  versions  of  SuperCharge:  20W  and  40W,  and  Huawei  also  manufacturers 
EPS that are able to deliver over 60W. HiSilicon does not produce SoC for other OEMs, 
and therefore only Huawei devices use Huawei SuperCharge. 

Huawei’s devices adjust the charging voltage and current automatically depending on the 
type  of  charger  and  cable  that  the  consumer  uses.  The  devices  also  disable  SuperCharge 
automatically when plugging in a cable that does not support SuperCharge.  

177 See list of devices featuring QC, as reported by Qualcomm, here: 
https://www.qualcomm.com/media/documents/files/quick-charge-device-list.pdf (updated November 2020) 

123 

 
                                                           
Huawei  SuperCharge  delivers  fast  charging  by  increasing  the  current  (up  to  8A),  and 
therefore it needs a cable that can transmit high current. Android Authority conducted the 
test using a OnePlus cable, which also delivers fast charging by increasing the current. Had 
Android  Authority  used  a  different  third-party  cable,  it  would  have  probably  failed  to 
deliver 20W. 

Huawei’s EPS use the proprietary SuperCharge  protocol  and can also  charge devices  via 
the USB Battery Charge protocol  (EN-IEC  62680-1-1). However, unlike  the devices, the 
EPS do not support USB PD. 

According  to  information  provided  by  interviewees,  all  Huawei  EPS  use  USB  Type-A 
sockets and they have no plans yet to move to USB Type-C at the EPS end. 

Oppo VOOC 

Oppo VOOC (Voltage Open Loop Multi-step Constant-Current Charging), also known as 
Dash  Charge  (20W),  Warp  Charge  (30W)  or  Dart  Charge  (65W),  is  a  proprietary 
technology  created  by  BBK  Electronics.  BBK  Electronics  Corporation  markets 
smartphones  under  the  Oppo,  Vivo,  OnePlus,  Realme  and  iQOO  (a  sub-brand  of  Vivo) 
brands. In contrast to other fast charging technologies (e.g. USB PD), which increase the 
voltage  during  fast  charging,  VOOC  uses  low  voltage  and  a  higher  current  than  the 
“common” charger.  

As of 2020, VOOC comes in five variations: (i) VOOC 2.0, which operates at 5 V/4 A, (ii) 
VOOC  3.0  (2019),  which  appears  to  operate  at  5  V/5  A,  (iii)  SuperVOOC  (2018),  a 
successor  of  VOOC  2.0  with  10  V/5  A  (50W),  (iv)  VOOC  4.0  (2020),  a  successor  of 
VOOC 3.0, which operates at 5 V/6 A (30 W), (v) SuperVOOC 2.0 (2020), a successor of 
Super  VOOC  with  10  V/6.5  A  (65  W).  All  versions  of  VOOC  require  a  proprietary 
cable  to  work.  In  addition  to  electrical  requirements  like  thickness  (low  electrical 
resistance)  to  handle  the  high  currents  without  overheating,  the  VOOC  2.0  protocol 
requires a fifth pin on the (USB-A to USB-C) cable to communicate through. Without such 
communication,  the  charger  runs  at  a  limit  of  5  V/1.5  A.  Mobile  devices  using  VOOC 
cannot  be  charged  at  a  fast  speed  using  non-proprietary  EPS.  A  Fast  Charging 
Accessory  test  conducted  by  Android  Authority  revealed  that  One  Plus  and  Realme 
devices charged at around 7W-13W when using Quick Charge or USB PD EPS, compared 
to 26W of power when charging with the original EPS and cable. According to IDC data, 
sales  of  VOOC-enabled  smartphones  in  2018  represented  less  than  1%  of  total  sales  of 
mobile  phones  in  the  EU.  The  mapping  of  devices  suggests  that  the  sockets  of  Oppo 
VOOC EPS are USB Type-A. 

Summary of interoperability between EPS and device 

In summary, most devices can be charged with a USB PD EPS (provided the right cables 
are connected) at a reasonable speed. This includes USB PD EPS, as well as QC 4+ and 
QC  5  EPS,  since  they  can  provide  power  using  the  USB  PD  mode  in  addition  to  their 
proprietary charging protocol.  

124 

 
Phone manufacturers are including either (a) USB PD as the only battery charging protocol 
in  their  devices,  or  (b)  USB  PD  in  combination  with  another  proprietary  solution.  This 
makes  these  devices  interoperable  with  any  USB  PD  compliant  EPS.  Oppo  devices  (e.g. 
OnePlus, Realme) are the least interoperable, and they can only be charged at high speed 
when  using  proprietary  accessories  (though  tests  show  that  USB  PD  can  charge  these 
phones at around 13W). 

As  shown  in  Figure  5.2,  in  some  instances  (e.g.  Huawei  and  Oppo  devices)  the  power 
provided by USB PD EPS is lower than their proprietary charging solution. This  may be 
because the USB PD protocol included in these devices use a low voltage (e.g. 5V or 9V at 
3A), whereas the proprietary solutions  can accept  higher wattage. USB  PD is  backwards 
compatible,  which  means  that  low-end  devices  which  still  use  the  standard  BC  protocol 
(EN-IEC 62680-1-1) can be charged safely (up to 7.5W). 

Figure 5.2. Summary of interoperability between the most common types of EPS and devices 

Type of EPS 

Common 
EPS 

USB 
PD 

QC  1, 
2, 3 

QC 4 

QC  4+, 
5 

Huawei 
SuperCharge  OPPO 

Standard 

USB PD 

QC 1, 2, 3 

QC 4, 4+, 5 

(1) 

e
c
i
v
e
d
f
o
e
p
y
T
Legend: 

Huawei 

OPPO 

Interoperability is not guaranteed 
Standard charge (up to 7.5W) guaranteed 
Fast charge (10-15W, but below maximum capability of device) 
Fast charge (optimum charge) 
No information available 

Source: Ipsos MORI 

(1) According  to  information  provided  by  interviewees,  Huawei  EPS  and  cables  can 
charge  other  mobile  phones  at  10W.  However,  tests  conducted  by  Android 
Authority showed that the proprietary cable is not interoperable with Google Pixel 
4. This is most probably because Google Pixel 4 blocks any cables that do not fully 
comply with the USB Type-C specification, or that have some add-ons. 

125 

 
 
 
 
  
 
 
 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Interoperability of connectors at the device end 

Finally,  the  cables  connecting  the  device  and  the  EPS  also  affect  the  interoperability.  At 
the  device  end,  the  most  common  connectors  are  USB  micro-B  and  USB  Type-C.  The 
latter  is  gradually  superseding  the  former  in  smartphones  and  tablets;  however,  USB 
micro-B continues to be the mainstream solution for devices that require less power (e.g. e-
Readers,  earbuds  and  headphones).  For  more  information  on  the  connectors  used  by 
different types of devices, see section 2.3.1. Apple has a proprietary connector, Lightning, 
which has been incorporated in all iPhones and some other Apple products since 2012 and 
continues to be used in the last generation of iPhones launched in 2020. Recent iPads and 
MacBook  have  USB  Type-C.  Apple  has  not  published  the  Lightning  specifications; 
however, it should be able to  carry, at  least,  up to  20W, which is the power accepted by 
iPhone 12. Apple devices (smartphones, tablets and laptops) are USB PD enabled and can 
be charged with any EPS that supports USB PD. 

In  summary,  interoperability  is  determined  by  the  EPS  and  the  cable  separately.  This 
means,  the  same  EPS  could  be  used  to  charge  several  devices  even  if  the  devices  use 
different cables/connectors, and the same cable could be used for several devices, even if 
they use different EPS (e.g. because they have different charging requirements). The figure 
5.3 below summarises the most common charging solutions available in the market. 

Figure 5.3. Summary of charging solutions 

Source: Commission’s contractor 

Market share of the USB technologies 

Figure 5.4 shows the expected trends of EPS and cables in the absence of actions.  

126 

 
 
 
Figure 5.4: estimated stock of EPS and charger cables 

Annual sales (with Smartphones + standalone) [units] 

Stock [units] 

EPS 

Cables 

Source: Commission’s contractor 

127 

 
 
 
 
 
 
 
 
ANNEX 6: COHERENCY MAPPING – RELATED PIECES OF EU LAW 

In  March  2020,  the  Commission  adopted  a  new  Circular  Economy  Action  Plan.  It 
announces  initiatives  along  the  entire  life  cycle  of  products,  targeting  for  example  their 
design,  promoting  circular  economy  processes,  fostering  sustainable  consumption,  and 
aiming  to  ensure  that  the  resources  used  are  kept  in  the  EU  economy  for  as  long  as 
possible.  

The  plan  presents  a  set  of  interrelated  initiatives  among  which  the  Circular  Electronics 
Initiative that includes, among others, the following sets of actions: 

  Adopting  regulatory  measures  for  electronics  and  ICT  including  mobile  phones, 
tablets and laptops under the Ecodesign Directive so that devices are designed for 
energy efficiency and durability, reparability, upgradability, maintenance, reuse and 
recycling;  

  Adopting regulatory measures on chargers for mobile phones and similar devices, 
including  the  introduction  of  a  common  charger,  improving  the  durability  of 
charging  cables,  and  incentives  to  decouple  the  purchase  of  chargers  from  the 
purchase of new devices. 

 

Improving  the  collection  and  treatment  of  waste  electrical  and  electronic 
equipment178 including by exploring options for an EU-wide take back scheme to 
return or sell back old mobile phones, tablets and chargers. 

Ultimately, the CEI’s main objectives are to:  

 

reduce e-waste and carbon/environmental footprints;  

  keep valuable resources in the EU through circular models;  

  create economic opportunities and incentives and enable consumers to make more 

sustainable choices;  

  ensure a harmonized approach across the single market.  

When  developing  the  approach  for  the  common  charging  and  unbundling  initiative  the 
above mentioned objectives should be taken into account. 

178 Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical 
and electronic equipment (WEEE), OJ L 
197, 24.7.2012, p. 38. 

128 

 
 
 
                                                           
Related  to  the  first  two  sets  of  actions,  three  concurrent  initiatives  on  Ecodesign  and 
Energy  labelling  analyse  in  depth  environmental  impacts  of  spare  parts,  repair  and 
maintenance  information,  disassembly  requirements,  preparation  for  re-use,  design  for 
reliability,  design  for  recyclability,  environmental  impacts,  battery  requirements,  and 
energy labelling for mobile phones, tablets and laptops. The specific sub-actions are: 

1.  Designing mobile phones and tablets to be sustainable – ecodesign179 

This  initiative  was  planned  under  the  Circular  Economy  Action  Plan  2020  and  is  in  line 
with European Green Deal objectives on efficient use of resources. It aims to ensure that: 

  Mobile phones and tablets are designed to be energy efficient and durable 

  Consumers  can  easily  repair  (incl.  access  to  spare  parts),  upgrade  and  maintain 

them 

 

It is possible to reuse and recycle the devices. 

2.  Energy  labelling  of  mobile  phones  and  tablets  –  informing  consumers  about 

environmental impact180 

This initiative complements the parallel implementing Regulation on ecodesign. It aims to 
introduce,  when  relevant,  labelling  requirements  that  support  ecodesign  by  giving 
consumers better information regarding product sustainability. 

3.  Review ecodesign requirements for computers and computer servers181 

This initiative aims to reduce the energy consumption of computers and computer servers 
by establishing minimum efficiency requirements and other performance criteria. This will 
result  in  a  decrease  of  CO2  emissions  and  deliver  financial  savings  for  European 
consumers. 

Related to the third set of actions under the Circular Electronics Initiative, the Commission 
is  working  on  the  management  of  waste  of  electrical  and  electronic  equipment 
(WEEE). 

The  Initiative  will  take  stock  of  ongoing  actions  to  increase  the  circularity  of  electronics 
value chains, taking into account the developments on the Sustainable Products  Initiative 

179 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12797-Designing-mobile-phones-
and-tablets-to-be-sustainable-ecodesign  
180 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12798-Environmental-impact-of-
mobile-phones-and-tablets-Energy-Labelling  
181 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1581-Review-of-ecodesign-
requirements-for-computers-and-computer-servers  

129 

 
                                                           
(SPI)182, which will be adopted at the end of the year, and will set out the Commission’s 
vision  for  the  way  forward,  in  particular  addressing  both  the  supply  side  (eco-design 
requirements) and demand side (establishing a right to repair).  

The  Initiative  will  also  highlight  elements  focused  on  other  phases  of  electronic  product 
lifecycles. In this regard, the Commission is currently undertaking actions which include:  

 

 

Improving  the  collection  and  treatment  e-waste,  including  exploring  options  for 
strengthening  incentives  for  take-back  and  return  of  small  EEE  (stored  in 
households including cables and chargers) with  a focus on mobile phones, tablets 
and laptops ; (Q2 2021)  

In  the  context  of  SPI,  introducing  a  digital  product  passport  to  increase  the 
information on product characteristics along the value chain and to consumers and 
facilitate product repair, upgrading, component recovery and reuse, and ultimately 
recycling. 

  A  review  of  EU  rules  on  restrictions  of  hazardous  substances  in  electrical  and 

electronic equipment;  

An exploratory study is being run on options for strengthening incentives for take-back and 
return of small EEE (stored in households including cables and chargers) with a focus on 
mobile  phones,  tablets  and  laptops.  The  consultants  have  been  tasked  with  assessing  the 
possible options at EU level that could be taken to strengthen the incentives to return both 
used  EEE  and  waste  EEE.  This  means  that  both  measures  which  extend  the  lifetime  of 
devices through reuse or other times of reverse supply chains and measures which improve 
the collection of waste EEE are being considered. However, at this stage it still not decided 
which kind of instrument and follow-up the Commission will take.  

Concurrently, the Commission will also increase the effectiveness of the current Ecodesign 
framework for energy-related products by adopting and implementing the Ecodesign and 
Energy Labelling Working Plan 2020-2024 (EELWP). This will be the first 5-year plan 
to combine formally the future priorities for the implementation of the Ecodesign Directive 
2009/125/EC and Energy Labelling Regulation (EU) 2017/1369.  

The  EELLWP  contains,  among  others,  a  specific  item  being  investigated  for  possible 
regulation  about  the  “universal  EPS”.  It  is  estimated  that  more  than  2  billion  External 
Power Supplies (EPSs), in the range from 0-120 Watts, are present on the European market 
today183.  This  is  partly  due  to  a  fragmentation  of  EPS.  However,  it  is  also  caused  by 

182 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12567-Sustainable-products-
initiative  
183 EIA overview report 2017 

130 

 
                                                           
business  practice,  where  it  is  common  to  supply  an  EPS  with  each  electronic  device  to 
make  sure  that  the  sold  product  is  charged  and  supplied  with  the  right  power  supply. 
Typically,  only  lower  priced  electronic  products  such  as  mobile  phones  and  wireless 
speakers may be sold without an EPS. A potential for material efficiency exists if an EPS 
could  be  used  during  a  longer  lifetime  than  just  for  the  lifetime  of  the  product  it  is 
delivered with. 

On the evolution of technologies, the industry consortium USB-IF184, has developed a full 
set of specifications to support a number of features ranging from delivering direct current 
at various voltages and with different, modulable intensity, but also including transmission 
of digital data such as images and audio over a single cable and using a single, harmonised 
interface. These developments by USB-IF turned into a set of standards by IEC that were 
endorsed by ESOs185. 

Finally,  a  revision  of  the  EPS  regulation  is  foreseen  in  2022.  EPSs  are  regulated  by 
Commission Regulation (EU) 2019/1782186 , which define an EPS as a device that meets 
the following criteria: 

 

it is designed to convert alternating current (AC) power input from the mains power 
source input into one or more lower voltage direct current (DC) or AC outputs; 

 

it is used with one or more separate devices that constitute the primary load; 

 

 

it  is  contained  in  a  physical  enclosure  separate  from  the  device  or  devices  that 
constitute the primary load; 

it  is  connected  to  the  device  or  devices  that  constitute  the  primary  load  with 
removable or hard-wired male/female electrical connections, cables, cords or other 
wirings; 

 

it has nameplate output power not exceeding 250 watts; and 

 

it is used with electrical and electronic household and office equipment included in 
its Annex I; 

184 www.usb.org  
185 EN IEC 62680-1-2 :2020 ; EN IEC 62680-1-3 :2018 ; EN IEC 62680-1-4 :2018 ; EN IEC 62680-1-5 
:2019 ; EN IEC 62680-1-6 :2019 ; EN IEC 62680-1-7 :2019 ; EN IEC 62680-1-8 :2019 ; EN 62680-1-1 
:2015 : EN 62680-2-2 :2015 ; EN 62680-2-3 :2015. 
186 Commission Regulation (EU) 2019/1782 of 1 October 2019 laying down ecodesign requirements for 
external power supplies pursuant to Directive 2009/125/EC of the European Parliament and of the Council 
and repealing Commission Regulation (EC) No 278/2009 

131 

 
                                                           
The  regulation  excludes  the  certain  power  supplies  (voltage  converters,  uninterruptible 
power  supplies,  battery  chargers  without  power  supply  function,  lighting  converters, 
external power supplies for medical devices, active power over Ethernet injectors, docking 
stations for autonomous appliances, external power supplies placed on the market before 1 
April 2025 solely as a service part or spare part for replacing an identical external power 
supply placed on the market before 1 April 2020, under the condition that the service part 
or  spare  part,  or  its  packaging,  clearly  indicate  ‘External  power  supply  to  be  used 
exclusively  as  spare  part  for’  and  the  primary  load  product(s)  it  is  intended  to  be  used 
with). 

132 

 
 
GLOSSARY 

Term or acronym  Meaning or definition 
CEAP 
CEI 
Connector 

Circular Economy Action Plan 
Circular Electronics Initiative 
electrical termination which is built according to a specific blueprint and interface 
Re-design  a  part  or  component  by  separating  two  previously  joint  parts,  such  as 
splitting  an  external  power  supply  (EPS)  with  a  non-detachable,  soldered  cable  into 
two  independent  parts  and  using  a  receptacle  +  plug  connection  to  connect  the  EPS 
with the cable  
Ecodesign and Energy Labelling Working Plan 2020-2024 

Decoupling 

EELWP 

e-waste 

Waste from electronic and electrical equipment 

External Power 
Supply (EPS) 

Fast charging 

GaN 
GHG 
Interface 
kt 

Lightning  

MEP 
MoU 
MS 
NLF 
Plug 

Proprietary 
charging solution  

Receptacle 

RED 
SoC 
SPI 

Unbundling 

Device  converting  alternating  current  (AC)  power  input  from  the  mains  into  direct 
current  (DC)  to  power  a  product  as  defined  in  Regulation  (EU)  2019/1782  on  eco-
design 

Term  commonly  used  to  indicate  an  EPS  supporting  one  of  more  power  delivery 
protocols  for  optimising  the  speed  of  charge  of  battery-powered  products  whilst 
ensuring  safety  and  durability  of  the  batteries  via  interaction  with  the  battery 
management module in the powered products. USB PD include different features for 
powering at 4 discrete voltage level (5, 9, 15 and 20 volt) PPS defines small voltages 
increases between 3 volt and 21 volt.  
Gallium Nitride 
Green House Gas 
Common word to define the receptacle (Female connector) 
Kilo tonnes 
Proprietary  connector  created  by  Apple  Inc.  introduced  in  2012  to  replace  its 
predecessor,  the  30-pin  dock  connector  and  used  in  a  few  products  such  as 
smartphones  and  pencils.  Devices  with  a  Lightning  receptacle  can  interoperate  with 
any  USB  products  as  fully  compatible  at  signal  and  electrical  level.  Cables  with  a 
lightning  plug  generally  have  a  standard  USB  Type-A  or  Type-C  plug  on  the  other 
end. As Type-C, it is fully reversible.   
Member of the European Parliament 
Memorandum of Understanding 
Member States 
Legislative Framework 
Male connector 
Charging  solution  adopted  by  a  single  organization  or  individual.  Ownership  by  a 
single organization  gives the  owner the ability to place restrictions on the use of the 
solution and to change it unilaterally. Specifications for proprietary solutions may or 
may not be published, and implementations are not freely distributed. 
Female connector 
Radio Equipment Directive 2014/53/EU 
System on a Chip 
Sustainable Products Initiative 
Selling a product or service separately when previously it had been sold together with 
others. In the context of this IA, it means selling an electronic device without a cable 
and/or external power supply. 

133 

 
 
 
USB  (Universal  Serial  Bus  specification)  is  a  set  of  specifications  developed  by  the 
USB  implementer  Forum  (USB-IF)  for  that  establishes  specifications  for  cables  and 
connectors  and  protocols  for  connection,  communication  and  power  supply  of 
electronic products. The USB specifications have been standardised in IEC EN 62680 
family of standards  
In  July  2012,  USB-IF  announced  the  finalization  of  the  USB  Power  Delivery  (PD) 
specification  (USB  PD  rev.  1),  an  extension  that  specifies  using  certified  PD  aware 
USB  cables  with  standard  USB  Type-A  and  Type-B  connectors  to  deliver  increased 
power  (more  than  7.5  W)  to  devices  with  larger  power  demand.  The  USB  Power 
Delivery specification revision 2.0 (USB PD rev. 2) was released as part of the USB 
3.1 suite. It covers the Type-C cable and connector with four power/ground pairs and 
a separate configuration channel. Revision 3.0 was released in 2017. 

It  has  been  the  first  USB  connector  and  still  widely  available  in  many  products  for 
backward compatibility. Most of the EPSs currently on the market for use with phones 
have a Type-A receptacle for plugging the cable to power the product.  

A  connector  (B-Plug  and  B-Receptacle)  defined  to  overcome  limitations  of  the 
previous  type-A  connector  and  having  a  number  of  variants.  The  most  common 
variant, called “Micro-B” is generally used in cheap products such as low-end mobile 
phones. 

USB 

USB PD 

USB Type-A 

USB Type-B 

USB Type C 

24-pin  USB  connector  system,  which  is  distinguished  by  its  two-fold  rotationally-
symmetrical  connector.  A  device  with  a  Type-C  connector  does  not  necessarily 
implement  USB  3.1,  USB  Power  Delivery,  or  any  Alternate  Mode:  The  Type-C 
connector is common to several technologies. 

WEEE 

Wireless charging 

Waste  of  electrical  and  electronic  equipment  (WEEE)  such  as  computers,  TV  sets, 
fridges and cell phones, which is the subject of Directive 2012/19/EU. 
Inductive charging (also known as cordless charging) uses an electromagnetic field to 
transfer  energy  between  two  objects  through  electromagnetic  induction.  This  is 
usually done with an inductive pad. Power is sent through an inductive coupling to an 
electrical device, which can then use that energy to charge batteries or run the device.  

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