Opinion of the Regulatory Scrutiny Board
Date: 2025-10-13
Institutions: European Commission, Regulatory Scrutiny Board
Subjects: EC conformity marking, EU energy label, ecodesign, electrical equipment, energy consumption, energy production, energy saving, market approval, technical specification, telecommunications equipment

EUROPEAN COMMISSION 

Brussels, 18.4.2024 
SEC(2025) 264 final 

REGULATORY SCRUTINY BOARD OPINION 

COMMISSION REGULATION  

laying down ecodesign requirements for external power supplies, wireless chargers, 
wireless charging pads, battery chargers for portable batteries of general use and USB 
Type-C cables, pursuant to Directive 2009/125/EC of the European Parliament and of 
the Council and repealing Commission Regulation (EU) 2019/1782 

{ C(2025) 6759 final } 

{ SWD(2025) 288 final } 
{ SWD(2025) 289 final } 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
REGULATORY SCRUTINY BOARD 

Brussels,  
RSB 

Opinion 

Title: Impact assessment / Review of Ecodeisgn requirements for external 
power supplies 

Overall 2nd opinion: POSITIVE 

(A) Policy context 

Ecodesign  provides  rules  at  the  product  design  stage  to  improve  the  environmental 
performance  of  products  placed  on  the  EU  market.  Existing  ecodesign  measures  are 
reviewed regularly to ensure they remain relevant, efficient, and effective in the light of 
technological and market developments.  

The product-specific legislation for external power supplies aims to ensure the placing on 
the  market  of  technologies  that  reduce  the  life-cycle  environmental  impact  of  external 
power  supplies  and  the  elimination  from  the  market  of  those  products  not  meeting 
improved standards. This report assesses possible ways to update ecodesign requirements 
for external power supplies (EPS). 

(B) Key issues  

The  Board  notes  the  substantial  clarifications  and  improvements  in  the  revised 
report. 

The Board gives a positive opinion. The Board also considers that the report should 
further improve with respect to the following aspects:  

(1)  The impacts of the options on competitiveness and innovation are not elaborated 
in  sufficient  detail,  in  particular  as  regards  EU  industry  compared  to  third 
country competitors. 

(2)  The  methodology  behind  the  chosen  scoring  system  requires  further 

clarification. 

(3)  The costs in scope of the One In, One Out approach are not presented clearly.  

  ________________________________   
Commission européenne/Europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel. +32 22991111 
regulatory-scrutiny-board@ec.europa.eu 

 
 
 
 
 
 
 
 
(C) What to improve 

(1)  The analysis of respective impacts on EU and third-country EPS manufacturers and 
operators is underdeveloped, and should include potential opportunities for EU industry 
to develop. The report should discuss to what extent the options will facilitate or not the 
transfer  of  EPS  manufacturing  from  third  countries  to  the  EU.  The  report  should  also 
provide further analysis on the impacts of options on the potential to innovate, including 
potential  trade-offs.  It  should,  in  particular,  analyse  any  effects  on  how  innovation, 
understood as product differentiation, could be affected if regulatory requirements would 
mean  moving  towards  a  more  harmonised  product  population.  For  example,  potential 
secondary  impacts  on  innovation  related  to  the  lifetime  of  charged  devices  should  be 
analysed. 
(2)  The choice of the specific scoring system, including the choice of introducing scoring 
thresholds  to  compare  alternative  options,  and  the  methodology  behind  the  applied 
rankings should be clarified and justified,  as  the  scoring system  plays  a  crucial  role  in 
determining the comparison and prioritisation of options. The validity of setting thresholds 
when absolute (or normalised) values already exist should be better justified. 
(3)  While the revised report presents the  assumptions and  a  comprehensive  sensitivity 
analysis with respect to the two behavioral assumptions on the reaction of the consumers 
to improved interoperability and the uptake of manufacturers of the voluntary unbundling, 
the report could be quantitatively corroborated with available evidence and the likelihood 
of  their  realisations/deviations  based  on  available  studies  and  analyses  not  necessarily 
directly related to the EPS but to the wider ecodesign framework. 

(4)  While  the  report  provides  ample  description  of  the  content  of  the  options  in  the 
annexes, it would benefit from a summarised description in the main body of the report, 
as well as why the different measures were combined to form the options as presented. 
The  report  could  also  more  clearly  explain  whether  there  are  gaps  in  the  coverage  of 
products due to the legal framework and/or technical constraints, including whether other 
legal instruments to address such gaps may be available.   

(5)  While the contribution to the EU energy efficiency target is not an objective of the 
initiative in itself, it could nevertheless be estimated for the options as part of the analysis 
of expected impacts. 

(6)  The revised report should include in its Annex 3 the obligatory table with costs and 
cost savings related to the One In, One Out approach, as total estimates (not in unit costs). 
The report should also provide explanation of all abbreviations. 

The  Board  notes  the  estimated  costs  and  benefits  of  the  preferred  option(s)  in  this 
initiative, as summarised in the attached quantification tables. 

2 

 
 
 
 
(D) Conclusion 

The DG may proceed with the initiative. 

If  there  are  any  changes  in  the  choice  or  design  of  the  preferred  option  in  the  final 
version of the report, the DG may need to further adjust the attached quantification 
tables to reflect this. 

Full title 

Revision  of  Commission  Regulation  (EU)  2019/1782  laying 
down ecodesign requirements for external power supplies (EPS) 
pursuant to Directive 2009/125/EC  

Reference number 

PLAN/2021/11755  

Submitted to RSB on 

18 March 2024 

Date of RSB meeting 

Written procedure 

3 

 
 
 
 
ANNEX: Quantification tables extracted from the draft impact assessment report 

The following tables contain information on the costs and benefits of the initiative on which 
the Board has given its opinion, as presented above. 

If the draft report has been revised in line with the Board’s recommendations, the content of 
these tables may be different from those in the final version of the impact assessment report, 
as published by the Commission. 

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

Amount 

Comments 

Direct benefits 

Environmental benefits  GHG emissions reductions: 70kt CO2eq 

yearly1 
Energy consumption reductions: 2.45PJ 
yearly 
e-waste reduction: 4.65 tonnes yearly 

Consumer benefits 

Purchase cost reductions: €101mln 
yearly 
Electricity costs reductions: €33mln 
yearly 
Consumer convenience of being able to 
use interchangeably an EPS for multiple 
applications, or when replacing a 
product. 
Better quality of EPS due to durability 
requirements. 

Economic benefits 

End-device manufacturers: €19mln 
yearly saved EPS costs. 

Incentivising the 
unbundling of EPS 
brings the biggest 
influence as regard to 
the reduction of the 
extraction of resources, 
manufacture, transport, 
use and disposal of the 
chargers.  
Additional savings are 
due to the energy 
consumption related 
requirements. 
Certain energy losses 
are due to the 
additional USB 
receptacles and USB 
cable resistances.  

The interoperability 
and extended reliability 
of EPS will bring a 
reduction of the 
purchases of standalone 
EPS and cables. 
Tightened (average 
active efficiency, no-
load losses) and newly 
introduced (low-load) 
minimum requirements 
reduce electricity costs, 
but slightly increase 
EPS costs.  

Additional turnover for 
refurbishment 
businesses 

1 Yearly benefits change over time: Energy related impact reductions reach a maximum around 2035 and are 
declining thereafter due to the on-going decarbonisation of the EU electricity grid mix, whereas impact 
reductions due to interoperability reach their maximum towards the end of the forecast period in 2040; for 
these reasons benefits are stated as „up to“ values 

4 

 
 
Indirect benefits 

Extended lifetime of 
end-devices 

Not quantifiable 

(refurbishment of 
devices with lost EPS): 
No data 

Broad availability of 
compatible 
replacements EPS in 
case of EPS defects 

II. Overview of costs – Preferred option 9.6 

Citizens/Consumers   Businesses 

Administrations 

(a) Measure 
on 
interoperab
ility – M2b   

Direc
t 
costs 
for 
EPS 
Direc
t cost 
for 
end-
devic
es 

Recurr
ent 

N/A  

One-off 

With each 
new EPS 
and 
product 
purchase 
additional 
costs: 
- €1.50 for 
EPS 
redesigned 
for USB 
- €1 for 
USB cable 
- €0.60 for 
surge 
protection 
of the USB 
EPS 
- €0.60 - €2 
for the 
USB 
compatibili
ty of the 
end-device 
(for 
products 
re-designed 
for USB 
compatibili
ty due to 
this 
regulation) 

One-off 

Recurrent  One-off  Recurrent 

Capacity 
for 
additional 
test 
requireme
nts: 
negligible 
costs. 

Not 
quantifiab
le 
New test 
requireme
nts to 
verify 
claimed 
USB 
compatibil
ity, but 
less 
product 
models in 
the market 
to be 
expected. 

EPS 
redesigne
d, USB 
cable, 
surge 
protection
. 
Loss of 
turnover 
by 
worldwide 
industries 
and retail 
channels 
in EU of € 
600mln 
yearly 
compared 
to the 
baseline. 
Loss of 
revenue 
due to no 
further 
sales of 
over-
priced 
proprietar
y 
replaceme
nt EPS. 

For 
manufactu
rers who 
already 
use USB 
Type C in 
the 
products in 
scope: 
N/A 
For 
manufactu
rers who 
do not use 
USB Type 
C in the 
products in 
scope: 
Costs to 
redesign 
the 
charging 
circuitry of 
the 
equipment 
(mitigated 
by a 
transition 
period) 
Savings on 
EPS costs 
in case 
device and 
EPS are 

5 

 
 
 
unbundled 
(depending 
on output 
roughly 
€1–10 per 
device); 
initially 
additional 
EPS costs, 
if bundled, 
for USB 
vs. 
convention
al EPS, 
cost 
increase 
expected 
to be 
absorbed 
by mass 
production 
synergies. 

N/A 

N/A 

N/A 

Indire
ct 
costs 

Losses in 
turnover 
due to 
slightly 
less end-
device 
sales 
(those, 
which 
would 
otherwise 
been 
replaced 
due to a 
defect 
EPS): Not 
quantifiab
le 

Increased 
EPS costs 
per unit: 
€0.04-
0.18 

N/A 

N/A 

N/A 

Additional 
tests costs 
for low-
load: 
negligible 

N/A 

N/A 

Increased 
EPS costs 
€0.04 - 
0.18 per 
unit in 
average 

(b) 
Measure on 
reducing 
energy 
consumptio
n – M4a  

Direc
t 
costs 

Indire
ct 
costs 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

6 

 
N/A 

N/A 

Capacity 
for 
additional 
test 
requireme
nts: 
negligible 
costs 

Increased 
EPS costs 
per unit: 
€0.06-
0.10 
Loss of 
turnover 
by 
worldwide 
industries 
and retail 
channels 
in EU of € 
100mln 
yearly 
compared 
to the 
baseline 

New test 
requireme
nts to 
verify 
claimed 
lifetime 
(time 
consumin
g test 
procedure
), test 
costs 
roughly in 
the range 
of €100 
per unit to 
be 
expected 

(c) Action 
on 
durability 
of EPS – 
M6 

Direc
t 
costs 

Increased 
EPS costs 
€0.06 - 
0.10 per 
unit in 
average 
due to 
higher 
lifetime 
electrolytic 
capacitors. 
The costs 
for 
detachable 
cables, i.e. 
additional 
USB-C 
receptacle 
and cable 
plug are 
not singled 
out and are 
considered 
under the 
measure on 
interoperab
ility (M2b) 

Indire
ct 
costs 

Direc
t 
costs 

(d) 
Measure on 
externalisat
ion of 
power 
circuitries 
of wireless 
chargers 
and  single 
cell battery 
chargers  
– M5 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

New 
market 
surveillan
ce actions 
on battery 
chargers 

N/A 

N/A 

Additional 
EPS costs, 
if separate 
EPS is 
purchased 
with 
battery 
charger: 
€5.00 (for 
cylindrical 
cell 
chargers). 
In the 
majority of 
cases use 
of an 
already 
existing 
EPS to be 
expected. 

7 

Additional 
costs on 
redesignin
g chargers 
for USB-
compatibil
ity, but 
also 
savings on 
bill-of-
materials 
costs for 
chargers 
with (as of 
now) 
integrated 
AC-DC 
circuitry, 
might 
materialis

 
e as 
additional 
revenue. 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Increased 
wireless 
charger 
costs per 
unit: 
€0.15 

New 
market 
surveillan
ce actions 
on 
wireless 
chargers. 

No 
significant 
changes to 
actual 
charger 
costs 
expected 

Increased 
wireless 
charger 
costs €0.15 
per unit 
(average) 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Indire
ct 
costs 

Direc
t 
costs 

Indire
ct 
costs 

(e) Action 
on stand-by 
requiremen
ts for 
wireless 
chargers  
– M4d 

8 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 
REGULATORY SCRUTINY BOARD 

Brussels,  
RSB 

Opinion 

Title: Impact assessment / Review of ecodesign requirements for external 
power supplies 

Overall opinion: NEGATIVE 

(A) Policy context 

Ecodesign  provides  rules  at  the  product  design  stage  to  improve  the  environmental 
performance  of  products  placed  on  the  EU  market.  Existing  ecodesign  measures  are 
reviewed  regularly  to  ensure  they  remain  relevant,  efficient,  and  effective  in  the  light  of 
technological and market developments.  

The product-specific legislation for external power supplies aims to ensure the placing on 
the market of technologies that reduce the life-cycle environmental impact of external power 
supplies  and  the  elimination  from  the  market  of  those  products  not  meeting  improved 
standards. This report assesses possible ways to update ecodesign requirements for external 
power supplies (EPS) 

(B) Summary of findings 

The  Board  notes  the  additional  information  provided  and  commitments  to  make 
changes to the report. 

However, the Board gives a negative opinion because the report contains the following 
significant shortcomings:  

(1)  The report does not adequately define the problem the initiative intends to address, 
including in terms of scope, energy efficiency and interoperability. It is unclear on 
the magnitude of the problem and the regulatory and energy efficiency gaps to be 
covered. The relationship with the Radio Equipment Directive is not sufficiently 
elaborated. 

(2)  The  logic  of  the  intervention  is  not  well  established.  The  problems,  problem 
drivers,  objectives  and  options  are  not  appropriately  described,  structured  and 
linked, nor are policy trade-offs clearly presented. The policy objectives are not 
expressed in specific terms and do not reflect  the legal  constraint that measures 
need to be set at lowest life cycle consumer cost. 

(3)  The robustness of the analysis of impacts of specific measures and options is not 
inadequate 

to  unclear  assumptions  and 

properly  demonstrated  due 
acknowledgment of uncertainties. 

9 

 
 
 
 
(4)  The  report  does  not  provide  an  adequate  comparison  of  options  in  terms  of 
effectiveness,  efficiency and coherence.  The  analysis  lacks clarity on  the  applied 
scoring of different criteria  and the  overall methodology  used in  comparing  the 
options. The choice of the preferred option is not adequately argued. 

(C) What to improve 

(1)  The report must put the initiative in a clearer context of the revised EU energy efficiency 
target  and  the  relevant  recent  policy  initiatives.  It  should  establish  (and  support  with 
evidence) what the initiative can contribute to the achievement of that target. It should clearly 
explain the articulation with the revised Radio Equipment Directive and better discuss the 
issue of interoperability in the context of the “common charger initiative,” and the regulatory 
gap that the initiative is intended to fill. The report should also better justify the need to act 
now  given  the  imminent  legislative  adoption  of  the  Ecodesign  for  Sustainable  Products 
Regulation  and  the  potential  constraints  of  the  existing  ecodesign  framework  in 
appropriately addressing the problem. The problem and its drivers should be defined in a 
broader way to reflect the issue of interoperability of EPS which features prominently in the 
subsequent analysis. The definition of the problem needs also to cover issues related to the 
scope of the initiative adequately. The report should clearly explain the choice of products 
and explain why precisely some products – such as e bike chargers -are not included.  

(2)  The redefined problems should closely link to better specified objectives. The objectives 
should be defined in a way that provides clear criteria to compare the options, be measurable 
so  as  to  establish  success  criteria,  and  reflect  any  potential  trade-offs  between  the 
environmental gains and consumer savings deriving from the ecodesign legal framework, in 
particular the legal constraint that measures need to be set at lowest life cycle consumer cost. 
The  structure  of  options  considered  in  the  report  should  be  fundamentally  reviewed, 
simplified  and  the  distinction  made  between  measures  and  options,  with  all  appropriate 
options defined and described in sufficient detail upfront, including a clear explanation of 
the concrete content. This is in particular the case for measures on active average efficiency, 
interoperability and wireless chargers. The report should justify more coherently why some 
of the options are discarded from further analysis, including more ambitious measures on 
stricter efficiency limits. All retained options should be analysed in a comprehensive way, 
including all the measures which should be described in detail, including for newly covered 
issues such as wireless chargers.  

(3)  As the impacts of specific options rely to a large extent on the reaction of consumers to 
interoperability  and  the  uptake  by  manufacturers  of  the  voluntary  unbundling,  the  report 
should clearly present what assumptions were used for these two issues and corroborate them 
with  available  evidence.  As  the  behavioural  aspects  are  associated  with  significant 
uncertainty  (which  should  be  acknowledged  more  explicitly),  the  report  should  provide 
sensitivity analyses with respect to those two key assumptions. The report should also clearly 
distinguish the impacts of the options  on competitiveness,  in particular  on  manufacturers 
located  inside  the  EU  as  opposed  to  third  country  producers.  It  should  better  assess  the 
impacts on innovation and how future proof the options are. 

(4)  The report should restructure the impact analysis so that it follows the revised option 
design. The modelling should be updated with the most recently available evidence and the 
calculation errors should be eliminated. The report should provide estimates of overall costs 
rather than only unit costs (including in the context of the ‘one in, one out’ approach cost 
estimates). It should also clarify how it uses the concepts of consumer and societal welfare 
and societal life cycle costs in the analysis.  

10 

 
 
(5)  The comparison of options should be revisited, following the restructuring of options 
and redefining the objectives. The retained options should be compared against the baseline 
as regards their effectiveness, efficiency,  coherence, and proportionality,  clearly applying 
the relevant criteria and the constraints from the ecodesign framework. The performance of 
options regarding  lowest life cycle consumer cost  should  be  synthetically  folded  into  the 
effectiveness  and  efficiency  assessments  in  line  with  the  revised  specific  objectives.  
Coherence of the options should be assessed both within the instrument and with respect to 
other  EU  policies  rather  than  third-country  technical  standards.  The  comparison  should 
clearly  present  trade-offs  reflected  in  the  choice  of  options.  The  choice  of  the  preferred 
option should be argued based on significantly reviewed comparison of options. This should 
include a clear explanation on the choice of the scoring system used to compare options and 
the  methodology  behind  the  applied  rankings.  Whatever  the  methodology  to  compare 
options is used, it must be supported by the analysis presented in the report.  

Some more technical comments have been sent directly to the author DG. 

(D) Conclusion 

The DG must revise the report in accordance with the Board’s findings and resubmit 
it for a final RSB opinion. 

Full title 

Revision  of  Commission  Regulation  (EU)  2019/1782  laying 
down  ecodesign  requirements  for  external  power  supplies 
(EPS) pursuant to Directive 2009/125/EC 

Reference number 

PLAN/2021/11755 

Submitted to RSB on 

27 September 2023 

Date of RSB meeting 

25 October 2023 

11 

Electronically signed on 18/04/2024 18:36 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121