COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Accompanying the document 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
Date: 2025-10-13
Institutions: Directorate-General for Energy, European Commission
Subjects: EC conformity marking, EU energy label, ecodesign, electrical equipment, energy consumption, energy production, energy saving, market approval, technical specification, telecommunications equipment

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   EUROPEAN COMMISSION  Brussels, 13.10.2025  SWD(2025) 288 final  COMMISSION STAFF WORKING DOCUMENT  IMPACT ASSESSMENT REPORT  Accompanying the document 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} - {SEC(2025) 264 final} - {SWD(2025) 289 final}  
 
 
Table of Contents 

1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT ............................................... 4 

1.1.  Implications of the ecodesign framework .................................................................................4 

1.2.  EU energy and climate objectives .............................................................................................5 

1.3.  The contribution of Ecodesign ..................................................................................................6 

1.4.  Importance of the regulation under review ...............................................................................7 

1.5.  Sustainable development goals .................................................................................................7 

1.6.  Legal context of the impact assessment ....................................................................................8 

1.7.  Impact of the revision of the Radio Equipment Directive ........................................................8 

2.  PROBLEM DEFINITION ..................................................................................................... 9 

2.1.  What are the problems?.............................................................................................................9 

2.2.  What are the problem drivers? ................................................................................................10 

2.3.  Who is affected by the problems, in what ways and to what extent? .....................................19 

2.4.  How likely is the problem to persist without intervention? ....................................................22 

3.  WHY SHOULD THE EU ACT?......................................................................................... 23 

3.1.  Legal basis ..............................................................................................................................23 

3.2.  Subsidiarity: Necessity of EU action ......................................................................................23 

3.3.  Subsidiarity: Added value of EU action..................................................................................24 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? ............................................................... 24 

4.1.  General objective ....................................................................................................................24 

4.2.  Specific objectives ..................................................................................................................24 

4.3.  Consideration of alternative objectives ...................................................................................25 

5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? .................................................... 26 

5.1.  The intervention logic .............................................................................................................28 

5.2.  What is the baseline from which options are assessed? ..........................................................28 

5.3.  The interactions between EPS efficiency, durability and interoperability ..............................29 

5.4.  Description of the policy options (POs) ..................................................................................30 

5.5.  Policy Options matrix .............................................................................................................32 

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

6.1.  Business-as-Usual (BAU) .......................................................................................................33 

6.2.  Economic impacts of the POs .................................................................................................33 

6.3.  Environmental impacts of the options ....................................................................................36 

6.4.  Social impacts .........................................................................................................................39 

6.5.  Impact on societal costs ..........................................................................................................39 

6.6.  Overview of the PO impacts ...................................................................................................40 

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7.  HOW DO THE OPTIONS COMPARE? ............................................................................ 41 

7.1.  How the options are compared ................................................................................................41 

7.2.  Determining the end-user lifecycle cost minimum level of EPS efficiency ...........................41 

7.3.  Effectiveness and efficiency of options ..................................................................................42 

7.4.  Scoring the options .................................................................................................................43 

7.5.  Ranking the options ................................................................................................................44 

8.  PREFERRED OPTION ....................................................................................................... 44 

8.1.  Legal requirements ..................................................................................................................44 

8.2.  Main impacts ...........................................................................................................................45 

8.3.  Verifying the missed environmental benefits of other options ...............................................45 

8.4.  Impact of consumer rate of reuse of EPS on the Preferred Option .........................................46 

8.5.  REFIT .....................................................................................................................................47 

8.6.  One-In One-Out ......................................................................................................................47 

8.7.  Concluding remarks ................................................................................................................48 

9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? ................. 49 

ANNEX 1: PROCEDURAL INFORMATION ....................................................................... 51 

ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ........................... 56 

ANNEX 3: WHO IS AFFECTED AND HOW? ..................................................................... 63 

ANNEX 4: ANALYTICAL METHODS ................................................................................. 70 

ANNEX 5: THE ECODESIGN AND ENERGY LABELLING FRAMEWORK .................. 88 

ANNEX 6: PRODUCTS IN SCOPE OF THE CURRENT EPS REGULATION .................. 90 

ANNEX 7: EVALUATION OF REGULATION (EU) 2019/1782 ON ECODESIGN 
REQUIREMENTS FOR EXTERNAL POWER SUPPLIES .................................................. 92 

ANNEX 8: THE SME TEST ................................................................................................. 135 

ANNEX 9: COMPETITIVENESS CHECK .......................................................................... 137 

ANNEX 10: LIST OF MEASURES AND PRELIMINARY ASSESSMENT ..................... 140 

ANNEX 11: DISCARDED MEASURES .............................................................................. 157 

ANNEX 12: SELECTION OF POLLUTANTS FOR ANALYSIS ....................................... 162 

ANNEX 13: SENSITIVITY TESTS ...................................................................................... 165 

ANNEX 14: ADDITIONAL IMPACTS OF THE POLICY OPTIONS ............................... 175 

ANNEX 15: VALUING CONSUMER (IN)CONVENIENCE ............................................. 177 

ANNEX 16: EVIDENCE UNDERLYING ASSUMPTIONS OF EXTENDED 
INTEROPERABLE EPS LIFETIMES .................................................................................. 180 

ANNEX 17: DETAILED COMPLEMENTARY AND SUPPORTING INFORMATION .. 185 

ANNEX 18: REFERENCES .................................................................................................. 188 

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 ACRONYMS 

AD 

Acidification 

IC 

Integrated Circuit 

ANEC 

European consumer voice in standardisation 

IEC 

International Electrotechnical Commission 

APPLiA 

Home Appliance Europe 

AVS 

BAU 

BEUC 

bn 

CAGR 

CECAPI 

CSL 

CO2 

CO2eq 

CONEBI 

CTP 

DIY 

DoE 

Adjustable Voltage Supply 

Business-as-usual 
Bureau Européen des Unions de 
Consommateurs 
billion 

Compound Annual Growth Rate 
European Committee of Electrical 
Installation Equipment Manufacturers 

Candidate Stringency Level 

Carbon Dioxide 

Carbon Dioxide equivalent 
Confederation of the European Bicycle 
Industry 
Climate Target Plan 

Do-it-yourself 

US Department of Energy 

ECOS 

Environmental Coalition on Standards 

EED 

EGMF 

EIA 

EMC 

EN 

Energy Efficiency Directive 
European Garden Machinery industry 
Federation 
Ecodesign Impact Accounting 

Electromagnetic Compatibility 

European Norm 

EPBA 

European Portable Battery Association 

External Power Supply 
European Power Supply Manufacturers 
Association 
European Power Tool Association 

IPx 

IT 

ITI 

ITU-T 

LCA 

LCC 

LVD 

Ingress Protection 

Information Technology 

Information Technology Industry Council 
International Telecommunication Union 
Telecommunication Standardization Sector 
Life-Cycle Assessment 

Life-Cycle Consumer Cost 

Low-Voltage Directive 

MEErP 

mln 

Methodology for Ecodesign of Energy-related 
Products 
million 

MTBF 

Mean Time Between Failures 

MoU 

MSA 

NACE 

NECP 

NOX 

PAH 

PM 

PO 

PoE 

POP 

PPS 

RED 

Memorandum of Understanding 

Market Surveillance Authority 
Nomenclature statistique des activités économiques 
dans la Communauté européenne 
National energy and climate plans 

Nitrogen Oxides 

Polycyclic Aromatic Hydrocarbons 

Particulate Matter 

Policy Option 

Power-over-Ethernet 

Persistent organic pollutant 

Programable Power Supply 

Radio Equipment Directive 

REF2020  EU Reference Scenario 2020 

REFIT 

Regulatory Fitness 

Electrostatic Discharge 
Ecodesign for Sustainable Products 
Regulation 
European Telecommunications Standards 
Institute 
Eutrophication Potential  

SDG 

SME 

SO 

SOx 

Sustainable Development Goals 

Small and Medium Enterprises 

Specific Objective 

Sulphur Oxides 

Gross Energy Requirement 

TFEU 

Treaty on the Functioning of the European Union 

Greenhouse Gas 

Global Warming Potential 

Heavy Metal 

Impact Assessment 

Integrated Circuit 

TS 

USB 

Technical Study 

Universal Serial Bus 

USB-IF 

USB Implementers Forum 

USB-PD  USB Power Delivery 

VOC 

Volatile Organic Compound 

International Electrotechnical Commission  WTO 

World Trade Organisation 

Ingress Protection 

ZVEI 

Zentralverband Elektrotechnik und Elektroindustrie 
e.V. 

EPS 

EPSMA 

EPTA 

ESD 

ESPR 

ETSI 

EUP 

GER 

GHG 

GWP 

HM 

IA 

IC 

IEC 

IPx 

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1.  INTRODUCTION: POLITICAL AND LEGAL CONTEXT 

This  Impact  Assessment  concerns  the  review  of  an  implementing  regulation  adopted  under 
the  Ecodesign  Directive  concerning  external  power  supplies  (EPS)1.  Through  setting 
harmonised minimum requirements and providing information, the regulation aimed to ensure 
an appropriate contribution from  EPS to  the EU’s energy, climate  and environmental  goals, 
while avoiding fragmentation of the internal market. 

1.1. Implications of the ecodesign framework 

The regulation under review is one of over thirty that has been adopted under the Ecodesign 
Directive.  This  creates  the  framework  within  which  the  intervention  can  be  elaborated  and 
therefore  for  this  Impact  Assessment.  These  factors  lead  to  certain  constraints  that  are 
outlined below. 

The  review  of  the  regulation  is  a  legal  obligation  created  by  the  existing  implementing 
regulation  and  EU  action  is  therefore  essential.  Underlying  this  obligation  to  carry  out  a 
review  is  the  hypothesis  that  continuing  innovation  and  technical  progress  will  have  led  to 
greater potential for energy savings and enhanced environmental protection. In view of this, it 
cannot  be  considered  that  there  is  a  regulatory  gap,  but  rather  there  is  a  need  to  explore 
whether revising the regulation can achieve greater benefit. 

By  its  nature,  ecodesign  unavoidably  involves  setting  detailed  technical  requirements. 
Ecodesign  reviews  follow  a  bottom-up  approach  exploring  all  technically  feasible  measures 
contributing  to  the  specific  objectives.  These  are  discussed  and  elaborated  with  relevant 
stakeholders over a period of time and this is documented in the Impact Assessment. 

A specific constraint from the Ecodesign Directive is that the energy efficiency requirements 
must in principle be set at the level corresponding to the least life cycle consumer cost. This 
means that unlike many EU interventions, it is not primarily based on overall societal welfare 
but  consumer  welfare.  However,  account  must  also  be  taken  of  the  environmental  impacts, 
suggesting  that  slightly  lower  or  higher  energy  efficiency  ambition  may  be  justified  for 
environmental reasons. While lowest lifecycle consumer cost is the broad constraint, account 
must  also  be  taken  of  affordability  and  therefore  any  increase  in  consumer  purchase  costs 
must be reasonable.  

Since ecodesign measures are intended to support the single market, it is largely considered to 
be inherent that they are necessary and have EU added value.  

Because  the  intervention  concerns  the  review  of  an  implementing  measure  adopted  under  a 
directive,  in  line  with  the  Better  Regulation  Guidelines  the  specific  objectives  of  the 
intervention are determined by the directive. In the case of ecodesign this means that they are 
to  achieve  1)  energy  savings  and  2)  environmental  protection  within  the  least  lifecycle 
consumer cost constraint. 

1 Commission Regulation (EU) 2019/1782. 

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1.2. EU energy and climate objectives 

The  EU  has  longstanding  objectives  to  increase  energy  efficiency  and  to  reduce  its 
greenhouse  gas  (GHG)  emissions.  These  go  along  with  other  objectives  to  reduce  its 
environmental  impacts.  In  December  2019,  the  Commission  presented  the  European  Green 
Deal2 to strengthen these objectives and as the cornerstone of its strategy to fulfil the United 
Nation’s  2030  Agenda  for  Sustainable  Development3.  In  September  2020,  it  presented  a 
Climate Target  Plan (CTP) for 20304, showing the need for a higher  contribution of energy 
efficiency  and  renewable  energy  to  achieve  a  net  55%  GHG  emission  reduction  most  cost-
effectively,  in  line  with  the  Paris  Agreement.  The  European  Parliament  and  Council 
subsequently  agreed  to  achieve  this  level  of  reduction  in  GHG  emissions.  The  Commission 
followed  this  by  proposing  the  “Fit  for  55”  package5  of  legislative  proposals  aiming  to 
achieve the necessary cut in GHG emissions. 

One  pillar  of  the  CTP  and  subsequently  the  ‘Fit  for  55’  package  is  energy  efficiency.  A 
revision of the Energy Efficiency Directive (EED)6 to increase the overall ambition has been 
agreed.  This  requires  Member  States  to  enhance  their  National  Energy  and  Climate  Plans 
(NECPs) to  achieve  at  least  an overall  11.7%  reduction in  EU energy consumption in  2030 
compared  to  the  reference7.  The  EED  itself  contains  limited  energy  saving  measures  and  in 
addition  to  Member  State  actions,  additional  measures  at  EU  level  are  needed8.  In  this 
context, the ecodesign rules for products are important instruments to realise the EU’s energy 
and  decarbonisation  objectives.  The  nature  of  the  market  failures  leading  to  unexploited 
energy  efficiency  potential  mean  that  it  is  essential  to  address  the  specific  barriers  in  many 
different  areas  and  products.  Each  area  may  on  its  own  lead  to  modest  energy  savings  but 
taken together they are essential to meet the overall reduction goal. 

Another  pillar  of  the  European  Green  Deal  is  a  more  circular  economy.  The  new  Circular 
Economy  Action  Plan9  sets  out  steps  to  work  towards  this.  It  aims  to  reduce  product 
environmental impacts for example through promoting longer product lives, greater resource 
efficiency and enhancing recycling and recycled content.  

Reducing energy use and promoting the circular economy are also important for many other 
reasons10.  Lower  energy  use  reduces  the  EU’s  energy  import  dependence  and  improves 
energy security. Recent  geopolitical  events  have  increased the  focus on  energy security and 
the  contribution  energy  efficiency  can  make  to  this.  The  Commission  “REPowerEU  Plan” 
Communication  aimed  at  rapidly  reducing  EU  dependence  on  Russian  fossil  fuels.  In-use 
energy savings from EPS will contribute to these goals. 

2 The European Green Deal, COM(2019) 640 final. 
3 Transforming our world: the 2030 Agenda for Sustainable Development. 
4 Stepping up Europe’s 2030 climate ambition. Investing in a climate-neutral future for the benefit of our people 
(COM/2020/562 final). 
5 ‘Fit for 55’: delivering the EU’s 2030 Climate Target on the way to climate neutrality, COM(2021) 550 final 
6 Proposal for a Directive of the European Parliament and of the Council on energy efficiency, COM(2021) 558 
final. 
7 EU reference scenario 2020 - Publications Office of the EU (europa.eu). 
8 These additional measures include not only ecodesign and energy labelling but also the EU ETS, vehicle CO 2 
legislation and the Energy Performance of Buildings Directive. 
9 ‘Circular Economy Action Plan for a more competitive Europe’, COM(2020) 98. 
10 https://www.odyssee-mure.eu/data-tools/multiple-benefits-energy-efficiency.html. 

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1.3. The contribution of Ecodesign 

There  are  market  barriers  that  hamper  the  introduction  and  uptake  of  more  energy  efficient 
and more long-lasting products. It is desirable for policies to address these barriers since they 
lead  to  unrealised,  economically  viable,  energy  and  material  savings.  Behavioural  failures 
refer to the cognitive limitations and biases that prevent consumers and investors to appreciate 
rationally  the  benefits  of  energy  efficiency11.  Market  failures  arise  from  the  fact  that  many 
impacts  and  aspects  of  energy  supply  or  resource  use  are  not  brought  into  market  prices12. 
Market  barriers  such  as  lack  of  information  and  awareness,  split  incentives  or  financing 
challenges  result  in  economically  rational  energy  savings  not  being  realised  or  more 
sustainable choices not being made.  

The Ecodesign Directive13 aims to address these barriers by setting performance requirements 
to  remove  the  worst  performing  products  from  the  EU’s  internal  market.  These  harmonised 
requirements have where appropriate specifically addressed energy efficiency and have led to 
significant  reductions  in  energy  use  of  household  and  industrial  products.  Other  minimum 
requirements can also be set e.g. pollutant emission limits. Being set at EU level, they have 
mitigated the risk of industry facing multiple, different national rules. The energy assessments 
aim to ensure that the minimum requirements are set at the level of Least Lifecycle Consumer 
Cost.  

The impacts of ecodesign coupled with energy labelling are estimated through the Ecodesign 
Impact  Accounting14  (EIA).  According  to  this,  in  2022  ecodesign  and  energy  labelling 
measures  combined  are  estimated  to  have  cut  EU  primary  energy  use  (and  related  GHG 
emissions)  by  about  12%,  saving  around  €90bn  unnecessary  EU  consumer  expenditure  per 
year  (€290  for  an  average  EU  household)  and  brought  numerous  other  environmental  and 
consumer benefits. An overview of the processes followed to adopt product measures under 
ecodesign is shown in Annex 5. 

Certain  circular  economy  aspects  can  be  addressed  through  measures  under  the  Ecodesign 
Directive  since  decisions  made  at  design  can  influence  the  product’s  life  span  and  ease  of 
maintenance,  repair,  reuse,  upgrade,  recyclability  and  waste  handling.  The  Ecodesign  and 
Energy  Labelling  Working  Plan  2022-202415,  as  in  the  previous  plan,  identified  ecodesign 
measures’  potential  to  contribute  to  circular  economy  objectives  and  subsequent  supporting 
studies have systematically considered resource efficiency aspects. 

Ecodesign also contributes directly or indirectly to other important policy objectives, such as 
improved  air  quality,  energy  system  integration  and  the  alleviation  of  energy  poverty.  It  is 
also expected to lead to the creation of jobs, encourage innovation and support and facilitate 
economic growth16. Both energy savings and promoting the circular economy lead to reduced 
environmental  damage  from  materials  extraction  and  resource  efficiency.  Most  of  these  co-
benefits are difficult to quantify, but are well known and perceived by society. 

11 DellaValle N., Bertoldi P. (2021) “Toward a more situated energy efficiency policy agenda”. 
12 E.g. impacts on air pollution, biodiversity, resource use, climate change and energy security. 
13  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). 
14 All EIA reports are available at: https://europa.eu/!Yphyry  

15 ‘Ecodesign and Energy Labelling Working Plan 2022-2024’; C(2022) 2026. 
16 https://combi-project.eu/2018/06/22/combi-results-overview-policy-conclusions/.  

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In March 2022, as flagged in the Circular Economy Action Plan, the Commission adopted, a 
proposal  to  replace  the  Ecodesign  Directive  with  an  Ecodesign  for  Sustainable  Products 
Regulation (the ESPR). The co-legislators reached agreement on the legal text at the end of 
2023. The ESPR will expand the scope of ecodesign from energy-related products to any kind 
of physical good placed on the market, with some exceptions. It would also slightly expand 
the  range  and  nature  of  requirements  that  could  be  set  in  regulations  adopted  under  it.  The 
most significant impact that the ESPR might have for the current review is  the expansion of 
the  scope  to  some  means  of  transport.  This  could  enable  EPS  for  transport  applications 
currently out of scope to be addressed in future and thus merits inclusion in a review clause. 

In  view  of  the  continuous  need  to  review  ecodesign  regulations  and  to  avoid  delaying  the 
benefits  that  can  be  delivered  from  those  reviews,  transitional  arrangements  for  ongoing 
reviews are included in the ESPR. The EPS regulation review is listed in the ESPR as one of 
the  measures  for  which  the  review  and  adoption  of  revised  measures  should  be  completed 
under the Ecodesign Directive. 

1.4. Importance of the regulation under review 

EPS are devices used to supply electricity to, and to charge built-in batteries of electronic and 
electric devices  (“end devices” or  "primary load  products") such  as laptops, mobile phones, 
tablets  and  electric  shavers.  For  other  products  without  built-in  batteries,  they  serve  as  the 
main continuous source of power – for example standalone loudspeakers or computer network 
equipment  such  as  modems  and  routers.  The  use  of  such  products  spans  both  domestic  and 
office  settings.  EPS  are  often  sold  bundled  with  these  products  and  in  view  of  the  large 
number of product sales, there are estimated to be around 400mln EPS sales per year in the 
EU.  

The  energy  consumption  of  EPS  are  essentially  the  losses  in  the  EPS,  whether  at  load  or 
unloaded.  The  EIA  estimates  these  losses  in  2020  at  about  11.6TWh  or  about  0.5%  of  EU 
final electricity consumption. Their GHG emissions due to losses in no-load and active mode 
amounted to 4.4Mt CO2eq, about 0.2% of EU CO2 emissions. The electricity use is associated 
with about 1.4kt of NOx and 1kt of SOx emissions in the EU in 2020 based on EEA figures on 
electricity sector pollutant emissions.  

EPS  are  mass-produced  with  production  largely  in  Asia.  The  2021  EIA  report  shows  an 
estimated 430mln EPS sold in the EU27 in 2020 and consumer expenditure for these products 
amounted to €6.5bn, split between €4.3bn acquisition and €2.3bn energy costs.  

1.5. Sustainable development goals 

In  addition  to  contributing  to  the  EU’s  energy  and  environmental  goals,  ecodesign  also 
contributes to some of the UN’s 17 Sustainable Development Goals (SDGs). Increased energy 
efficiency  and  product  circularity  contribute  to  SDG  7  (affordable  and  sustainable  energy), 
SDG  8  (sustainable  economic  growth),  SDG  12  (responsible  consumption  and  production) 
and SDG 13 (climate action). In particular they contribute to achieving the following targets:  

• 

• 

• 

target 7.3 (double the energy efficiency improvement rate);  

target 8.4 (improve resource efficiency in consumption and production); 

target 12.2 (sustainable management and use of natural resources); 

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• 

• 

target 12.5 (substantially reduce waste generation);  

target 13.2 (integrate climate change measures). 

Annex 3 includes a discussion on whether and in how much these goals are being served. 

1.6. Legal context of the impact assessment 

This impact assessment relates to the review of Commission Regulation (EU) 2019/1782 on 
ecodesign  requirements  for  external  power  supplies,  (hereafter  ‘the  Regulation’).  Further 
information on the products covered by the regulation and the energy they use is provided in 
Annex 6: Products in scope of the current EPS regulation. 

The fact  that there is  continual  innovation  improving  the potential technical  performance of 
these  products  and  that  learning  leads  to  lower  production  costs  lead  to  the  hypothesis  that 
over time additional potential will arise for cost effective strengthening of the requirements.  
In  view  of  this,  Article  7  of  the  regulation  requires  it  to  be  reviewed  in  the  light  of 
technological  progress  by  14  November  2022.  The  review  should  in  particular  assess  the 
following aspects (the ‘R’ numbers enable identification of how these specific aspects of the 
review are addressed later in the IA):  

• 

the feasibility of setting a requirement regarding minimum energy efficiency at 10% 
load (R1);  

•  options for including within the scope of the Regulation:  

o  wireless chargers (R2),  
o  active power over Ethernet injectors (R3), and  
o  external  power  supplies  used  with  electrical  and  electronic  household  and 

office equipment that is not included in Annex I (R4);  

•  options  for  including  requirements  in  support  of  circular  economy  objectives, 

including interoperability (R5). 

The review of the regulation was announced in the Ecodesign and Energy Labelling Working 
Plan  2022-2024.  This  indicated  that  the  review  would  also  examine  how  circular  economy 
aspects  such  as  resource  efficiency,  reparability,  recyclability,  and  durability  could  be 
assessed and addressed if appropriate.  

1.7. Impact of the revision of the Radio Equipment Directive 

A  large  share  of  the  EPS  regulated  by  the  regulation  are  used  to  power  products  that  are 
regulated  by  the  Radio  Equipment  Directive  (RED)17.  Two  recent  amendments  to  the  RED 
introduce a ‘common charging’ solution for those products. 

•  Directive (EU) 2022/2380 defines the ‘common charging’ requirements; 

•  Commission  Delegated  Regulation  (EU)  2023/1717  updates  the  wired  charging 

technical specification references. 

17 Directive 2014/53/EU 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 

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The RED requirements apply to the powered products, but do not  regulate directly the EPS.  
The  products  covered  are  handheld  mobile  phones,  laptops,  tablets,  digital  cameras, 
headphones,  headsets,  portable  speakers,  handheld  videogame  consoles,  e-readers,  earbuds, 
keyboards,  mice,  and  portable  navigation  systems.  The  requirements  apply  to  all  except 
laptops from 2024 and to laptops from 2026. 

A key requirement relevant to the review of the EPS  regulation is the requirement for RED 
products  to  be  charged  via  a  USB-C  port  on  the  device.  This  requirement  ensures  that 
consumers can charge their devices with any USB-C charger and that the vast majority of EPS 
of RED devices are USB compatible. A second key requirement is that producers must offer 
the option of buying the RED product without an EPS. A third key requirement is the need for 
harmonised information on the EPS needed to power the product. In view of the relevance of 
these factors for the EPS regulation, the Commission committed to promote interoperability 
by  introducing  corresponding  requirements  on  the  EPS  side  and  provide  consumers  with 
information related to the EPS. 

2.  PROBLEM DEFINITION 

An  evaluation  of  the  Regulation  has  been  carried  out  as  set  out  in  Annex  7.  During  the 
evaluation,  stakeholder  views  were  sought  on  aspects  that  merit  review.  This  work  led  to 
conclusions  on  the  desirability  of  considering  further  development  of  the  regulation.  These 
considerations  also  take  into  account  wider  political  priorities  and  policy  initiatives.  The 
problems relevant to this Impact Assessment have been identified following these reflections. 

2.1. What are the problems? 

2.1.1.  The first problem: unexploited potential for the EPS regulation to contribute 

to more rapid reduction in energy use and GHG emissions.  

The CTP demonstrates how EU energy use and GHG emissions need to reduce on a route to 
zero net GHG emissions by 2050. The CTP impact assessment explored various scenarios, the 
main  ones  of  which  were  REG,  MIX  and  CPRICE18.  The  ‘Fit-for-55’  legal  proposals  were 
subsequently based upon the CTP MIX scenario.  

The  revised  EED  adopted  as  part  of  the  Fit  for  55  package  set  a  headline  objective  for 
reducing  energy  consumption.  While  the  EED  itself  contains  some  measures  to  increase 
energy efficiency, a large share of the reductions need to come from other measures such as 
ecodesign.  

The IA supporting the EED proposal shows that by 2030 energy consumption per household 
is projected to be 31% lower than in 2020, and projects a 54% reduction in GHG emissions 
for the residential sector compared to 2015, far higher than for industry and transport.  

18  Impact  Assessment  accompanying  the  Communication  from  the  Commission,  ‘Stepping  up  Europe’s  2030 
climate ambition Investing in a climate-neutral future for the benefit of our people’; SWD/2020/176 final. 

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Achieving  the  2050  Zero  Net  GHG  emission  target  already  requires  substantial  steps  to 
achieve  the  2030  reduction  targets,  i.e.  sharp  reductions  of  energy  consumption  and  related 
GHG  emissions.  It  is  desirable  for  cost-effective  energy  efficiency  measures  to  be 
implemented to enable these overall targets to be achieved in the cheapest way for society. 

The  life  cycle  energy  consumption  of  EPS  contributes  to  overall  energy  consumption  and 
GHG emissions both in and outside the EU. It should therefore be explored whether they can 
be further reduced as a contribution to the overall reductions needed.  

2.1.2.  The  second  problem:  unexploited  potential  to  reduce  other  environmental 

impacts of EPS  

Apart  from  energy  use  and  GHG  emissions,  EPS  also  contribute  to  other  environmental 
impacts such as pollutant emissions from electricity generation due to material consumption 
as  fuel  and  the  consumption  of  materials  and  the  accompanying  environmental  impacts  for 
manufacture.  

Annual EPS sales represent about 22kt of materials, around 0.1% of material consumption in 
sales of all Ecodesign regulated products. The electricity used to power them results in over 
2Mt of fuel combusted annually. Pollutant emissions from this electricity generation amount 
to  about  1.4kt  of  NOX  and  1kt  of  SOX  in  2020.  The  pollutant  emissions  from  the 
manufacturing stage are likely to be considerably higher due to them being carried out in less 
well regulated conditions outside the EU. 

There  may  be  opportunities  to  reduce  these  other  environmental  impacts  arising  from  EPS 
manufacture and use. The amount of materials used for manufacture is determined both by the 
design  of  EPS  and  how  they  are  used,  including  their  lifetime.  If  ways  can  be  identified  to 
enable the same needs to be met with less EPS this will reduce the environmental impacts of 
the raw material supply and manufacturing processes as well as need for end of life treatment. 
The combustion of materials as fuel and the pollutant emissions from it are consequences of 
the electricity used by EPS. Reductions in EPS electricity use will lead to reductions in these 
problems.  

Overall  actions  that  can  reduce  these  environmental  impacts  will  contribute  to  the  EU’s 
Circular Economy objectives and its Zero Pollution action plan.  

2.2. What are the problem drivers? 

2.2.1.  Scope unclear and too narrow (D1) 

The current scope of the regulation does not cover EPS for a number of devices with growing 
markets. These will be of increasing relevance for energy efficient charging and power supply 
to  minimize  energy  consumption  and  potentially  allow  interoperability.  Some  examples  of 
these are battery charging devices, battery powered devices and gadgets, gardening and power 
tools, and e-bikes. 

In  addition,  questions  received  by  the  Commission  in  the  past  years  reveal  a  number  of 
uncertainties over the scope of the Regulation. Some examples are whether unbundled (stand-
alone) EPS are in scope, or whether EPS (e.g. USB sockets) contained in another product like 
a wall socket, socket cube, or table top lamp are addressed by it.  

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An unclear scope hampers market surveillance and creates uncertainties among producers as 
to  their legal  obligations and opens potential loopholes that undermine the objectives of the 
regulation.  

2.2.2.  No transparency on efficiency and potential for higher efficiency (D2) 

The energy efficiency differences between compliant EPS are considerable, reaching around 
five percentage points as illustrated in  Figure  1.  Additional  evidence  on this is  presented in 
Annex 7. 

Figure 1 - Average Active Efficiency External Power Supplies, AC-DC, except low voltage and multiple voltage 
output (Fraunhofer IZM) 

The spread of efficiency shows there is potential for greater energy savings. Further technical 
evolution,  including  for  example  different  types  of  semiconductors  should  enable  higher 
energy efficiency and thus potentially a wider spread in efficiency.  

The  resistance  of  the  cable  supplying  power  from  an  EPS  to  the  end  device  plays  a  non-
negligible role in the overall efficiency of the supply of power due to the higher currents that 
are used than at mains voltage. The losses in the cable are linearly related to the current drawn 
by the end device and the duration of time during which power is drawn from the EPS.  

The  differences  in  efficiency  are  not  visible  to  users  who  could  otherwise  purchase  more 
efficient  ones  thus  spurring  competition  on  efficiency  as  is  observed  as  a  result  of  energy 
labels. Because most EPS are sold bundled with an appliance and due to the split incentive, 
there is little motivation for the product supply chain to provide more efficient bundled EPS.  

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2.2.3.  EPS less efficient under low load (D3) 

EPS efficiency decreases at low load, i.e. if the EPS provides power or charges a device with 
less than 50% of its maximum performance, and steeply declines when approaching the 10% 
load level and lower.  

The average active efficiency of EPS is assessed at 25%, 50 %, 75% and 100% load, referred 
to as the four-point efficiency.  Figure 2 illustrates that two EPS with similar overall measured 
four-point  efficiency19  can  exhibit  large  efficiency  differences  in  the  low  load  area  starting 
with  around  3.6%  difference  at  25%  load  and  increasing  to  around  8%  at  10%  load.  The 
average efficiency thus may not reflect well the actual efficiency in daily operation. 

Figure 2 - Low load performance and average efficiency (Source: Flavio Cucchietti) 

Figure  3  shows  the  very  limited  correlation  between  active  average  efficiency  and  the 
efficiency  at  low  load  for  around  100  commercial  EPS.  This  confirms  that  a  high  active 
average efficiency cannot be taken as a proxy for a high efficiency at low load for the same 
device. 

19 The average of the efficiency measured at 25%, 50%, 75% and 100% load. 

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Figure 3 - Low load performance and average efficiency 

Lower load operations of EPS are common because EPS are dimensioned to accommodate the 
full power need of the powered device. Figure 4 illustrates that an EPS powering a notebook 
operates below 25% of its maximum load capacity for around 50% of its total operation time, 
and even more than 90% of the time at a load level below 50%. The efficiency of the low load 
area, and the efficiency at 10% are therefore pertinent to the overall energy losses of the EPS.  

Figure 4 - Distribution of loads over the operation time of a notebook (Source: Flavio Cucchietti) 

However,  because  there  is  a  lower  power  throughput  at  10%  load,  the  loss  due  to  a  1%pt 
lower efficiency at 10% load will be proportionately less than due to a 1%pt lower efficiency 
at higher load. In view of this the actual loss and therefore benefit from increasing 10% load 
efficiency will depend on the expected load profile and be within the area bounded by the two 
lines as shown in Figure 5.  

Taken  together,  these  factors  reveal  potential  for  efficiency  improvements  for  the  low  load 
range  of  EPS.  If  interoperable  EPS  are  used  for  charging  a  range  of  different  products,  the 

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operation time of such EPS in the low load area may even increase further leading to lower 
average conversion efficiencies and higher energy losses.  

Figure 5 - Impact of load and load profiles on EPS losses 

2.2.4.  Lacking interoperability of EPS (D4) 

EPS are generally not interchangeable because they have different operating voltages, power 
ratings  and  connectors.  The  result  can  confuse  and  inconvenience  consumers  and  leads  to 
higher expenditure due to the need to purchase a new EPS with almost every device.  

This  has  been  illustrated  by  a  consumer  survey  (IA  Common  Charger  2019)  that  showed  a 
certain  confusion  over  which  EPS  to  use  for  different  mobile  phones  and  other  electronic 
devices, and a degree of inconvenience for having too many EPS taking up space at home or 
at the workplace. 

Most of the detailed consumer issues documented have been addressed by the revision of the 
Radio Equipment Directive (RED), which requires the equipment in its scope to bear a USB-
C receptacle and be chargeable using the USB-C or USB-PD protocol. However, it should be 
noted that there are mobile phone models on the market which are assumed to be chargeable 
with  USB-PD  EPS,  but  are  sold,  bundled  or  not,  with  a  high  power  /  high  speed  charger20 
which is not USB-PD compliant and is therefore not usable with other end products.. 

The recently revised Batteries Regulation21 requires through its review article the assessment 
of the introduction of harmonised standards for a common charger for rechargeable batteries 
incorporated into equipment other than those in the RED scope. Since battery chargers consist 
of  a  power  supply  section  and  a  charging  section,  this  aspect  is  also  relevant  to  regulatory 
requirements concerning the interoperability and efficiency of EPS in general. 

20 https://www.mi.com/global/product/xiaomi-120w-charging-combo-type-a/. 
21 Article 94 of Regulation 2023/1542. 

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In  the  absence  of  interoperability,  EPS  cannot  generally  be  reused  and  therefore  there  is  a 
higher level of EPS purchases than if they were interoperable. As a result there is in aggregate 
a  greater  use  of  materials  in  their  manufacture.  The  increased  processing  of  the  necessary 
additional  raw  materials,  manufacture,  distribution,  sales  and  end  of  life  disposal  of  the 
greater number of EPS lead proportionately to higher environmental impacts.  

2.2.5.  Lack of information on compatibility with load (D5) 

Consumers have difficulty to decide whether an EPS is compatible with the load of a specific 
device since the information, if provided, is often hardly readable due to small fonts used and 
due to the broad range of information placed on EPS nameplates. Such technically complex 
information may also ask too much from consumers. As a result, consumers are confused and 
possible damage may arise if inappropriate EPS are used to power devices. This situation is a 
barrier to consumers reusing existing EPS for other products, even if they are interoperable, 
and creates uncertainty for them.  

Consumer  NGOs  have  raised  the  issue  that  consumers  may  have  difficulty  knowing  which 
cables are suitable for use with different loads. 

2.2.6.  Bundling of EPS with products (D6) 

Consumers have become used to receiving an EPS with each device. This experience creates 
an  expectation  that  products  should  be  delivered  with  an  EPS  rather  than  that  an  additional 
EPS should only be purchased if it is actually needed by the consumer.  

A majority of consumers on the one hand support at least the option of unbundling, but at the 
same  time  an  even  larger  majority  expects  an  EPS  and/or  cable  to  be  supplied  with  each 
product  for  performance  and  convenience  reasons.  Manufacturers  are  therefore  concerned 
about consumers’ reactions if they stop selling EPS with their devices. Moreover, producers 
selling unbundled products are afraid of losing control over the quality of the EPS used with 
their  products  due  to  potentially  counterfeit,  substandard  and  unsafe  EPS  placed  on  the  EU 
market (IA Unbundling 2021).  

There  is  however  evidence  from  the  same  analytical  work  that  unbundling  of  the  EPS  is 
becoming  common  in  certain  categories  of  products.  This  is  for  example  the  case  for 
hearables, e-readers, and portable speakers, whilst it is rare for portable videogame consoles 
and tablets. As regards the cable, this is almost always provided in the box with all types of 
devices.  

In  addition  to  consumer  expectations,  another  factor  at  play  is  that  some  harmonized 
standards  also  require  manufacturers  to  sell  specific  EPS  with  certain  products.  More 
information is provided on this matter in Section 2.2.8.  

Bundling  of  EPS  prevents  the  environmental  benefits  from  interoperable,  harmonized 
common  chargers  being  realised  and  may  reduce  the  environmental  benefits  from  more 
energy efficient EPS that could be used for longer. Such EPS may require more and/or better 
electronics  so  that  the  individual  higher  efficiency  EPS  may  have  higher  manufacturing 
impacts compared to lower efficiency ones. These aggregated impacts will be reduced if less 
EPS are purchased. 

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2.2.7.  Scope and testing of adaptive EPS (D7) 

The  testing  requirements  for  adaptive  EPS  are  not  fully  clear  and  the  Commission  has 
provided  clarifications  through  an  FAQ  to  address  the  uncertainties  raised.  Particular 
problems  are  the  application  of  the  different  limit  values,  the  testing  of  multiple  voltage 
output devices, and the USB cable used in the test.  

Such  uncertainties  and  incongruencies  adversely  affect  the  energy  savings  achievable, 
complicate  market  surveillance,  hamper  competition  and  limit  the  effectiveness  and  proper 
enforcement of the regulation.  

2.2.8.  Requirements arising from legislation and standards (D8) 

Bundling requirements for certain types of EEE 

According  to  APPLiA22  the  EN  60335-1  standard  requires  class  III  construction  parts  of 
household appliances such as tooth brushes, shavers, epilators, etc., to be sold with a power 
supply for safety reasons to prevent consumers using power supplies that are not safe with wet 
use  appliances.  The  producers  state  that  unbundling  requirements  for  household  appliances 
would therefore conflict with this normative requirement.  

In its current status, the harmonized standard EN 60335-1 does not allow unbundling of such 
wet use devices so that standardized EPS, even if they were specified for use only for class III 
construction devices, would not result in sales of less EPS. The bundling requirement is not 
directly stipulated by the Low Voltage Directive23 (LVD), but it is the EN 60335-1 standard 
which transposes safety and other requirements into provisions for manufacturers to follow in 
their product specifications and designs.  

Safety requirements for wet-use applications 

EN60335-2-8 and EN60335-2-52 require the use of IPX4 transformers with pins for insertion 
into  sockets  outlets  “for  washable/wet  shavers,  washable/wet  clippers,  washable/wet 
epilators,  wireless  toothbrush  chargers”.  Unbundling  would  force  consumers  to  purchase 
more expensive IPX4 chargers, or consumers may otherwise use chargers that are unsafe to 
use  in  wet  environments  unless  all  USB-PD  EPS  would  have  to  meet  these  safety 
requirements.  According  to  (APPLiA  2022),  IPX4  chargers  with  USB-C  connectors  are  not 
commonly  available and expensive.  Industry experts estimate an additional  €2-3 cost  for  an 
EPS to be made wet-use compliant24.  

Improved surge protection for IT and other electronic equipment 

Similarly, electronic products which are not so called end-of-line equipment like for example 
a  mobile  phone,  but  are  connected  to  other  devices  via  a  network  or  other  type  of  shielded 
cable, like for example a wireless router, require sometimes a higher level of electromagnetic 
protection from their EPS. This is needed for example because the common earth/shield can 
be an entry point for disturbances or surge which may damage the EPS. For this reason, such 
EPS are required by product manufacturers to be subject to higher electromagnetic immunity 

22 APPLiA response to EPS call for evidence (APPLIA 2022). 
23 Directive 2014/35/EU 2014. 
24 Several exchanges with the manufacturer FRIWO. 

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standards  according  to  specific  sections  of  EN  55035.  In  addition,  the  practice  of  certain 
telecom  operators25  is  to  require from their  equipment  higher protection levels,  for example 
according to the ITU-T K.21 recommendations. This is to prevent large scale failures of their 
routers  due  to  poor  earth  connections  in  many  residential  buildings.    Industry  experts 
estimated an additional cost of around €0.3 for a conventional EPS to become compliant with 
such higher levels of EMC protection.  

Electrostatic discharge protection for vacuum cleaners 

A  considerable  amount  of  electrostatic  charge  can  accumulate  on  a  vacuum  cleaner  during 
use. This charge can be released when connecting a handheld vacuum cleaner to its  EPS. In 
order  not  to  damage  the  EPS,  it  has  to  be  designed  to  withstand  a  very  high  level  of 
electrostatic discharge, for example in accordance with the standard IEC 61000-4-2.  

Toys 

Toys are by definition intended for use by children and must fulfil special safety precautions, 
which  apply  also  to  their  power  supply.  These  are,  for  example,  given  by  the  IEC  61558 
standard.  If  a  toy  is  expected  to  be  operated  outdoors,  its  power  supply  must  also  be 
IP65/IP67 protected. 

Audio equipment 

There  are no specific rules  or standards known to apply  only  to  the EPS of  audio  products. 
Nevertheless  it  appears  that  very  often  the  quality,  in  particular  the  noise  of  the  EPS  of  an 
audio product can impact the performance of the product itself. For this reason it appears that 
linear power supplies are often preferred for high-end audio applications instead of the more 
common  switch  mode  power  supplies.  This  would  normally  not  be  a  concern  for  other 
product groups.  

In addition, industry claims that audio products have a more pronounced peak power demand 
to  their  power  supply  than  other  product  groups.  This  is  illustrated  Annex  16.  If  such 
occasional  peaks  are  higher  than  the  maximum  USB-PD  power  of  240W  they  cannot  be 
supplied by this power supply.  

2.2.9.  Wireless charging and power over ethernet (D9) 

Wireless charging  

The wireless supply of power to  devices is  currently not  within the scope of the regulation. 
However, its prevalence in the market is increasing and a technical support study26 estimates 
worldwide shipments will reach 2bn integrated receivers (i.e. devices with wireless charging 
functionality) by 2025. Most high-end smartphones already include this  feature. The market 
for wireless charging27 was estimated to be worth around $5.3bn in 2021 and is expected to 
grow  at  an  annual  average  rate  of  23%  to  around  $35bn  by  2030.  The  driver  for  this 
development is user convenience.  

25 Like for example Telecom Italia. 
26  TS Wireless Charging 2021. 
27  C.f.  Strategic  Market  Research,  https://www.strategicmarketresearch.com/market-report/wireless-charging-
market. 

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The  emergence  of  wireless  charging  challenges  the  current  definition  of  a  power  supply,  as 
this  feature  includes  a  wireless  charging  pad  connected  to  the  EPS  via  a  cable.  The  overall 
efficiency of the supply of power to the device is thus dependent on system performance, not 
only on the efficiency of the EPS.  

Table 1 shows that wireless charging technologies have differing levels of efficiency. These 
are  inherent  to  the  technology  and  far  lower  than  the  efficiency  of  regular  EPS.  Within  the 
same  wireless  charging  technology,  for  example  Qi  chargers,  the  efficiency  can  differ 
considerably28.  The  Qi  charging  technology  dominates  the  current  market,  but  new  and 
proprietary  technologies  are  under  development.29  The  various  technologies  are  not 
interoperable.  

Qi (inductive) 

AirFuel (resonant) 

~ 50%  

40%  

Table 1 - Energy efficiency of wireless charging technologies (TS Wireless Charging 2021) 

The  power  requirements  of  different  wireless  charging  standards  may  cause  further 
interoperability  issues  for  EPS.  The  most  common  standard  Qi,  in  both  its  Baseline  Power 
Profile (up to 5W of power delivery) and its Extended Power Profile (up to 15W) can work 
with both USB-PD and standard EPS. Some proprietary wireless charging solutions, however, 
already exceed USB-PD base power profile and could therefore offer slower charging if used 
with a non-proprietary EPS. 

Active Power-over-Ethernet injectors 
Power-over-ethernet (PoE) avoids the need for a power source or an additional cable attached 
to a device with ethernet connection, by using the spare wires from the ethernet cable to carry 
the power  as  shown in  Annex 16. A distinction is  made between passive PoE injectors that 
provide  a  fixed  voltage  supply  without  a  compatibility  check,  and  active  PoE  injectors  that 
verify  and  control  the  voltage  to  be  supplied  to  the  powered  device,  also  ensuring  its 
protection. Passive PoE injectors are in the scope of the current regulation, while active PoE 
injectors are explicitly excluded. shows an outline of a PoE setting. 

PoE  injectors  are  increasingly  used  in  offices  and  housing30.  The  global  market  for  PoE 
injectors  is  expected  to  grow  from  around  $724mln  in  2020  to  around  $1.37bn  in  2029 
(CAGR of 9.5% from 2023 to 2029). This roughly translates into around 6.8mln PoE injectors 
sold  in  the  EU  in  2029  assuming  a  market  share  of  25%  and  an  average  price  of  $50  per 
device. 

In terms of energy efficiency, one and two port active PoE injectors (midspans) can be found 
in  specialised  internet  shops  with  between  65%  to  more  than  90%  efficiency,  some  are 
declared  to  comply  with  US  Department  of  Energy  (DoE)  level VI.  For  four  and  more  port 
injectors,  normally  no  efficiency  information  is  provided,  but  for  a  few  75%  efficiency  is 
declared  or  compliance  with  DoE  level  V31.  For  many  PoE  injectors,  no  efficiency  is 

28https://www.chip.de/bestenlisten/Bestenliste-Qi-Ladegeraete--index/index/id/1456/, and 
https://debugger.medium.com/wireless-charging-is-a-disaster-waiting-to-happen-48afdde70ed9. 
29https://www.electronicdesign.com/power-management/article/21805792/whats-the-difference-between-qi-and-
other-types-of-wireless-power-transfer. 
30 https://www.maximizemarketresearch.com/market-report/global-poe-injectors-market/39273/.  
31https://www.digikey.de/de/products/filter/power-over-ethernet-poe/138. 

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indicated. Common internet shopping platforms for consumers were found not to provide any 
efficiency information at all.  

The  large  efficiency  differences  between  active  PoE  injectors,  and  the  lack  of  information 
about efficiencies can be expected to result in unnecessarily high energy consumption in this 
growing market. From the declared high efficiencies and DoE level VI compliance for some 
active  PoE  injectors  it  could  be  understood  that  compliance  with  efficiency  requirements  at 
the current level in the Regulation is feasible at least for a part of the product spectrum (with 
lower  numbers  of  ports).  The  broad  range  of  indicated  efficiencies  point  to  a  large 
improvement  potential  which  could  remain  untapped  as  long  as  active  PoE  injector  are 
outside the scope of the future regulation.  

2.3. Who is affected by the problems, in what ways and to what extent? 

The  problems  described  above  are  understood  to  mostly  affect  consumers,  the  environment 
and economic operators. A brief summary of impacts per group is presented below. 

2.3.1.  Consumers 

The  minimum  efficiency  requirements  in  the  regulation  are  estimated  in  the  EIA  to  reduce 
consumers’  energy  cost  by  around  €1.2bn  in  2030.  However,  the  further  technical  potential 
for  saving  energy  and  reducing  consumers  costs  will  not  be  fully  exploited  if  the  current 
situation  persists.  Since  consumers  have  no  information  on  the  efficiency  of  EPS  on  the 
market, they cannot choose more efficient ones to reduce their energy costs even if they are 
inclined to do so.  

Consumers  will  also  be  exposed  to  additional  expenditure  as  they  end  up  purchasing  more 
EPS than needed. Consumers lack clear guidance on which EPS to use with which device as 
well as a multiplicity of connectors so that they are not in a position to decide whether they 
need to purchase an EPS with a new device or whether they can use one they already have. To 
end  this  situation,  consumers  need  clear  information  on  interoperability  and  interoperable 
EPS.  

Growing numbers of products use EPS outside the scope of the regulation such as gardening 
tools  and active PoE injectors. These EPS  are  not  subject  to  energy efficiency requirements 
and any harmonization. For these products consumers can thus not benefit from cost savings 
due to reduced energy use or the possibility of purchasing less EPS.  

Finally,  consumers  suffer  inconvenience  due  to  the  current  situation  regarding  chargers  for 
phones  and  other  portable  devices,  Among  the  reasons  put  forward  were  the  inability  to 
charge certain devices with certain chargers, the lack of clear information on interoperability, 
and the abundance of chargers at home. 

The Common Charger IA did not gather solid data on the user experience related to other kind 
of products, e.g. household appliances. However, considering that the fragmentation situation 
is at least comparable, a similar situation can be expected. 

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2.3.2.  Environment 

The current regulation is forecast to save around 5.4TWh electricity consumption and 0.8Mt 
CO2eq. per year in 2030. However, there are technical efficiency potentials which the current 
minimum  active  energy  efficiency  and  no-load  energy  consumption  requirements  do  not 
exploit to further reduce energy consumption and GHG emissions. There is also potential for 
extending the requirements to products that are currently out of the scope of the Regulation. If 
these  potentials  remain  untapped  the  potential  to  achieve  the  associated  GHG  and  pollutant 
emissions savings will not be exploited.  

Related 

emissions 

are 

connected 

to 

all 

life 

cycle 

stages 

of 

the  EPS. 

Table 2Table 2 below shows GHG emissions per life cycle phase for various representative 
EPS types, calculated with the EcoReport LCA tool. From this it is clear that the use phase 
emissions  are  dominant  in  all  but  one  use  case.  The  production  phase  is  the  next  largest 
contributor. Distribution and end of life have a minor role in overall emissions.  

Table 2 - Estimated GHG emissions for specific EPS units in kg CO2 and % per life cycle phase (reference year 
for carbon intensity of the electricity grid: 2020) 

The projected overall emissions will change largely as a result of changes in the stock and in 
the  GHG  intensity  of  electricity  supply.  Due  to  the  decreasing  GHG  intensity,  they  are 
estimated to decrease to 1.2Mt of CO2eq in 2030 in the EU. 

As  a  result  of  the  electricity  consumed  during  use,  there  are  also  substantial  amounts  of 
material consumed as fuel in its generation. In 2020 there were around 0.3t of fuel combustion 
avoided per MWh of electricity use avoided. This would mean that the energy losses in EPS 
currently lead to around 2.3Mt of fuel combustion annually. 

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Base CaseProductionDistributionUseEoLProductionDistributionUseEoLa. EPS ≤ 6 W, low-V (e.g. mobile phone)0.630.071.07-0.0637%4%63%-4%b. EPS 6-10 W (e.g. tablets, smart phones etc.)0.630.092.12-0.0623%3%76%-2%c. EPS 10-12 W (e.g. small network equipment, set-top boxes) 0.740.097.1-0.19%1%91%-1%d. EPS 15-20 W (e.g. portable devices, portable game consoles)1.230.271.98-0.1136%8%59%-3%e. EPS 20-30 W (e.g. notebook computer)1.390.273.65-0.1327%5%70%-3%f. EPS 30-65 W, multiple-V (e.g. multi-device univ. chargers)1.840.270.51-0.1775%11%21%-7%g. EPS 30-65 W (e.g. high-end notebook computers)3.050.277.26-0.2830%3%70%-3%h. EPS 65-120 W (e.g. high-end notebook computers)4.550.2711.89-0.4228%2%73%-3%i. EPS 65-120 W, multiple-V (e.g. stationary game consoles)4.550.275.27-0.4247%3%54%-4%j. EPS 12-15 W (e.g. loudspeakers, sound systems)0.630.090.74-0.0645%6%53%-4%21%3%78%-2%Stock weighted average in 2030:  kg CO2eq. per unit % of total for unitGreenhouse Gas emissions per life cycle phaseBase CaseProductionDistributionUseEoLProductionDistributionUseEoLa. EPS ≤ 6 W, low-V (e.g. mobile phone)0.630.071.07-0.0637%4%63%-4%b. EPS 6-10 W (e.g. tablets, smart phones etc.)0.630.092.12-0.0623%3%76%-2%c. EPS 10-12 W (e.g. small network equipment, set-top boxes) 0.740.097.1-0.19%1%91%-1%d. EPS 15-20 W (e.g. portable devices, portable game consoles)1.230.271.98-0.1136%8%59%-3%e. EPS 20-30 W (e.g. notebook computer)1.390.273.65-0.1327%5%70%-3%f. EPS 30-65 W, multiple-V (e.g. multi-device univ. chargers)1.840.270.51-0.1775%11%21%-7%g. EPS 30-65 W (e.g. high-end notebook computers)3.050.277.26-0.2830%3%70%-3%h. EPS 65-120 W (e.g. high-end notebook computers)4.550.2711.89-0.4228%2%73%-3%i. EPS 65-120 W, multiple-V (e.g. stationary game consoles)4.550.275.27-0.4247%3%54%-4%j. EPS 12-15 W (e.g. loudspeakers, sound systems)0.630.090.74-0.0645%6%53%-4%21%3%78%-2%Stock weighted average in 2030:  kg CO2eq. per unit % of total for unitGreenhouse Gas emissions per life cycle phase 
 
 
 
 
Life Cycle Assessments (LCA) such as conducted by SustainablySMART and more recently 
the  LCA  of  the  Fairphone  4,  which  includes  the  charger,  indicate  that,  among  the  charging 
components, the EPS is dominant in most impact categories. The Common Charger IA using 
a  stock  model,  estimated  that  the  raw  material  use  in  EPS  for  mobile  phones  and  similar 
devices could reach a peak of 15kt by 2022 and remain steady until 2028.  

Similarly,  an  upward  trend  is  expected  in  e-waste  generation  due  to  growing  purchases  of 
EPS.  The  Common  Charger  IA  model  estimated  an  increase  from  11kt  in  2022  to  13kt  in 
2028.  Clearly,  since  the  Common  Charger  IA  had  a  limited  product  scope,  the  level  of 
material use and e-waste generated is greater if a wider end product scope is considered. 

More efficient EPS would reduce the energy use and GHG and other emissions in use and the 
associated material combustion.  Interoperable, harmonized EPS in combination with a degree 
of unbundling would avoid a proportion of the environmental impacts by leading to a lower 
demand  for  new  EPS  which  would  reduce  the  energy  and  material  use  and  emissions  from 
production.  

It  can  be  concluded  that  continuation  of  the  current  situation  will  mean  that  energy 
consumption,  use  of  material  resources,  e-waste  and  the  associated  GHG  and  pollutant 
emissions will all continue at a higher rate than could be achieved. 

2.3.3.  Economic operators 

Manufacturers and suppliers of EPS have an interest in cost-effectively  minimising material 
use in the EPS. However, they lack any interest in the energy efficiency of the EPS and there 
is  no  competition  on  efficiency.  It  is  likely  that  interoperability  of  EPS  will  be  contrary  to 
their interest since it can be expected to lead to a reduction of EPS sales. Such a reduction of 
sales would lead to lower turnover and potentially to lower profits and employment. 

In view of this economic operators, including producers of equipment within and outside the 
scope  of  the  current  directive,  benefit  from  the  current  situation  with  commercial  and 
competitive  advantages  due  to  proprietary  solutions  for  connectors,  charging  protocols,  and 
economic  benefits  from  selling  EPS  with  the  products.  The  revision  of  the  RED  can  be 
considered to largely address the issue of interoperability for devices within its scope. 

It is likely that individual producers would fear being at a competitive disadvantage if they do 
not  meet  the  expectations  of  those  consumers’  expecting  to  be  provided  with  an  EPS  with 
each  product.  For  some  types  of  devices,  in  particular  for  wet-use  household  appliances, 
producers  experience  barriers  arising  from  current  standards  and  specifications  which  they 
cannot overcome as individual producers.  

Manufacturers claimed in the context of the Common Charger IA that further harmonisation 
may reduce incentives for research and innovation, thus blocking or delaying the emergence 
of newer and better charging technologies. The IA references the example of the relevance of 
Lighting connectors for the creation of USB Type C.  

Due to similarities in the current situation, the same concerns and potential effects are to be 
expected in manufacturers of EPS units for other product groups like vacuum cleaners and for 
other household appliances like devices used in wet conditions. 

Changes  to  the  ecodesign  requirements  are  not  expected  to  have  any  significant  impact  on 
competitiveness  of  economic  actors  as  assessed  in  Annex  9,  nor  in  consequence  to  the 

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attractiveness  of  manufacturing  EPS  in  the  EU.  However,  it  is  to  be  noted  that  if  there  is 
greater  interoperability  of  EPS  it  may  remove  opportunities  for  individual  manufacturers  to 
distinguish their products through proprietary solutions and thus reap higher profit. 

2.4. How likely is the problem to persist without intervention? 

EPS  for  energy-related  products  that  are  out  of  the  scope  of  the  current  Regulation  are  not 
subject to energy efficiency requirements. In combination with the lack of transparency as to 
the efficiency of these EPS, it is not likely that a significant share of this part of the market 
will move towards higher efficiency EPS.  

High  EPS  efficiency  across  the  entire  load  range  reflecting  technical  progress,  and 
transparency  on  actual  average  EPS  efficiency  cannot  be  expected  to  be  achieved  for  a 
sufficiently  large  portion  of  the  market  without  intervention  increasing  the  minimum 
efficiency requirements and/or creating transparency on average EPS efficiency.  

In  view  of  the  fact  that  EPS  tend  to  be  supplied  with  products  but  are  expected  to  have  a 
longer  life  than  the  product,  there  has  been  little  interest  in  EPS  durability.  The  current 
Regulation  therefore  does  not  contain  any  durability  requirements.  Without  a  generalised 
reuse of EPS there would be no interest for industry to produce more durable EPS. 

Problems arising from the current Regulation like the unclear scope and uncertainties as to the 
testing  of  adaptive  EPS,  cannot  be  solved  without  amending  it.  Similarly,  legal  and  other 
normative barriers (standards) addressed as problem drivers cannot be overcome by individual 
producers but need to be addressed by policy interventions to initiate adaptations of normative 
requirements.  

The conditions and factors driving the lacking interoperability of EPS in the absence of a clear 
standard for interoperability – e.g. producers seeking competitive and commercial advantages 
with  proprietary  charging  protocols,  consumers’  experiences  and  uncertainties  as  to  the 
interoperability of EPS – foreseeably  are  not  likely  to  change without intervention.  Without 
extension of the regulation’s scope these fragmentation tendencies for products currently out 
of scope are expected to continue.  

It  has  been  reported  (IA  Unbundling  2021)  that  voluntary  unbundling  initiatives  by  certain 
mobile phone manufacturers could result in an estimated 25% of phones being sold without 
an EPS and that could increase further. However, experience with the implementation of the 
MoU32, shows not all manufacturers will follow, especially those with proprietary solutions. 
The  IA  found  no  unbundling  initiatives  for  household  appliance  EPS  and  identified  market 
fragmentation due to proprietary connectors and charging protocols. 

It  is  therefore  not  likely  that  the  market  will  move  towards  a  harmonised,  common  charger 
which can be used for a broad range of different types of energy-related products in the scope 
of  the  Regulation  such  as  information  technology  devices,  household  appliances,  consumer 
equipment, without intervention.  

32

 For more information on the 2009 Memorandum of Understanding (MoU), see: https://ec.europa.eu/growth/sectors/electrical-

engineering/red-directive/common-charger_en. 

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Without intervention, the other identified problem drivers are also likely to persist or will not 
change to the degree that enables the full potential which EPS can contribute to reduce energy 
consumption, material use and GHG and pollutant emissions to be realised. 

3.  WHY SHOULD THE EU ACT? 

3.1. Legal basis 

Article 114 of the Treaty on the Functioning of the European Union (TFEU) is the legal base 
for  measures  related  to  the  functioning  of  the  internal  market  and  therefore  constitutes  the 
legal base for the Ecodesign Directive and its derived legislation.  

The  Ecodesign  Directive  lays  down  in  its  Article  15(2)  a  set  of  criteria  to  identify  energy-
related products that may be subject to ecodesign measures. EPS are eligible since they satisfy 
the  requirements  on  annual  sales,  have  a  significant  environmental  impact  in  the  EU  and 
present significant potential for improvement of their environmental impact on the basis of the 
potential energy and material savings that can be achieved through the introduction of  cost-
effective measures. 

3.2. Subsidiarity: Necessity of EU action 

The  intervention  is  a  review  of  an  existing  regulation.  In  preparing  that  regulation  it’s 
necessity was assessed by verifying that the EU market for EPS had sufficient size to justify 
the  development  of  specific  products  and  that  the  other  requirements  justifying  action  were 
met. This existing regulation contains a review clause that obliges the EU to act. 

In view of the urgency of cutting energy use and GHG emissions in line with EU targets, all 
significant opportunities for increasing energy efficiency need to be exploited. Since market 
failures mean that regulatory action is  essential to exploit  those opportunities, achieving the 
overall EU goals requires it to identify and exploit them to achieve this. In the absence of EU 
action on EPS, Member States might implement restrictions on certain types of products.  

The  scale  of  the  change  means  that  the  evolution  towards  lower  energy  use  and  GHG 
emissions  needs  to  be  carried  out  in  the  least  cost  manner  for  society.  To  achieve  cost 
effective action, it is essential to avoid national restrictions and that requirements for products 
are set at EU level to preserve the single market. 

The  mobilisation  of  EU  industry  for  a  clean  and  circular  economy  requires  uniform 
requirements to be set for a sufficiently large market. This requires that action to increase the 
efficiency  of  energy-related  products  such  as  EPS  and  reduce  their  environmental  impacts 
needs to be carried out at EU rather than national level.  

These factors point to the need to set stricter minimum requirements determining access to the 
market  for  EPS  to  ensure  they  make  an  appropriate  contribution  to  EU  goals.  Ecodesign 
measures need to be taken at EU level since they act directly on the product, which means that 
uniformity  must  be  assured  to  avoid  different  national  rules  that  would  undermine  the  EU 
internal market for that product. 

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3.3. Subsidiarity: Added value of EU action 

Ecodesign  measures  contribute  to  the  global  EU  energy  and  climate  objectives  by  setting 
requirements  that  influence  the  technical  characteristics  of  energy  related  products.  The 
ecodesign  framework  has  the  added  value  of  requiring  those  requirements  to  be  set  at  least 
lifecycle consumer cost which therefore ensures that they contribute to achieving the overall 
objectives at least cost.  

These  requirements  differ  from  many  other  energy  and  climate  legislation,  that  effectively 
require Member States to implement or promote solutions based on existing technologies, in 
that they require or promote the deployment or development of better technologies. In view of 
this they will have the added value of more effectively promoting innovation. 

Direct  EU  action  through  ecodesign  rules  reinforces  other  actions  that  may  be  taken  at 
Member State level. The added value of EU action on EPS was determined in preparing and 
adopting the existing regulation. 

4.  OBJECTIVES: WHAT IS TO BE ACHIEVED? 

It  is  important  to  identify  the  general  objective  so  that  the  proposed  initiative  can  be 
understood  in  the  overall  context  of  the  Union's  policies.  This  also  enables  a  future 
assessment of if, and how, the initiative has contributed to its achievement.  

4.1. General objective 

The general objective is to contribute to the EU’s energy and environmental objectives while  
ensuring the functioning of the internal market, as set in the Treaty on the Functioning of the 
European Union.  

The TFEU states that the aim of EU energy policy includes ensuring security of energy supply 
and promoting energy efficiency and energy saving33. Lower energy consumption is usually 
accompanied  by  a  reduction  in  other  environmental  impacts  including  GHG  and  pollutant 
emissions as well as lower resource use and extraction.   

4.2. Specific objectives 

The specific objectives aim at correcting the problems identified in section 2. They are:  

1.  Reduce  the  life  cycle  energy  consumption  of  EPS  at  the  lowest  lifecycle  consumer 

cost (SO1) 

2.  Reduce the GHG emissions and other environmental impacts of EPS (SO2)  

There  are  synergies  between  SO1  and  SO2.  Reducing  electricity  consumption  of  EPS  to 
achieve SO1 leads to lower combustion of fuel and reduced GHG and air pollutant emissions 

33 Article 194 TFEU, paragraph 1. 

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contributing to SO2. Similarly, EPS reuse contributing to SO2 through the use and production 
of  less  EPS  also  reduces  the  energy  consumption  for  material  production,  processing, 
manufacturing, transport and packaging contributing to SO1. 

In  principle  more  efficient  EPS  generate  less  heat,  allowing  more  compact  designs  that 
require less material, thus reducing manufacturing impacts. This is shown in response to Q2.5 
of the evaluation. The lower heat generation itself should result in less stress on components, 
in  particular  electrolytic  capacitors,  thus  helping  to  prolong  EPS  lives  (when  they  are 
reusable) and thus reduce the need for replacement purchases.  

There might be trade-offs if lower energy consumption to achieve SO1 were achieved though 
more complex EPS or require different materials if these lead to larger environmental impacts 
contrary to SO2.  

4.3. Consideration of alternative objectives 

It  might  be  considered  that  there  are  other  specific  objectives  for  the  intervention  such  as 
increasing the scope or enhancing interoperability. However, these are both possible measures 
that  are  implemented  with  the  objective  to  reduce  energy  and  environmental  impacts  and 
therefore  should  not  be  viewed  as  objectives  in  their  own  right.  Since  both  can  only  be 
achieved  in  one  specific  way,  they  would  appear  to  be  contrary  to  the  Better  Regulation 
guidance  to  ensure  that  objectives  “be  broad  enough  to  allow  consideration  of  all  relevant 
policy alternatives without prejudging a particular solution”. In view of this, the objectives 
are kept as those set in the framework legislation. 

It might be considered that the objective of reducing environmental impacts should be better 
disaggregated  into  specific  elements.  Since  reducing  the  amount  of  material  used  leads  to  a 
reduced  environmental  impact,  this  might  be  considered  as  an  objective.  However,  material 
consumption in itself is not an environmental impact and therefore would appear to be open to 
legal  challenge  if  used  as  a  basis  for  determining  the  stringency  of  a  regulation  under  the 
Ecodesign Directive. Even separating actual environmental impacts into different objectives, 
e.g. GHG and pollutant emissions, or emissions to air and water, raises the difficulty that the 
objective is to reduce environmental impact overall, not limited to one category. Any trade-
offs between the impacts in different categories need to be clear in the overall contribution to 
the environmental objective. In view of this, environmental impacts are assessed together and 
aggregated on the basis of their estimated monetized values. 

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5.  WHAT ARE THE AVAILABLE POLICY OPTIONS? 

The  review  of  the  regulation  started  in  March  2022.  This  is  a  back-to-back  Evaluation  and 
Impact  Assessment.  Evidence  gathering  and  analytical  work  has  been  done  through  a 
supporting contract and has involved meetings with stakeholders as well as interviews. A Call 
for  Evidence  was  published,  and  feedback  gathered  from  6  April  2022  -  4  May  2022. 
Extensive  desk  research  and  other  evidence  gathering  such  as  EPS  testing  has  fed  into  the 
process. A consultation forum meeting was held in February 2023 to set out the work on the 
evaluation and Impact Assessment and discuss working documents and a further meeting was 
held in November 2023. A summary of stakeholders’ main inputs is provided in Annex 2. 

This  process  has  enabled  a  thorough  exploration  of  weaknesses  in  the  current  legislation  as 
well  as  reflection  on  the  evolution  needed  in  view  of  the  overarching  climate,  energy  and 
environmental  policy  goals.  Through  these  discussions  a  wide  range  of  possible  measures 
have been identified and explored. Some of the possible measures that have eventually been 
discarded are: 

1.  Setting requirements for repairability 
2.  Harmonisation and active efficiency requirements for wireless charging 
3.  Introducing an EU Energy Label 
4.  Voluntary agreement by the industry 
5.  Extension of the scope to certain other products 
6.  Introduction of information requirements on efficiency 
7.  Interoperability requirements for certain product categories 
8.  Obligatory unbundling EPS from the products they power 

A detailed description of these measures and the reasons for their discarding are provided in 
Annex 11.  

After this analysis a set of measures remain including, where appropriate, different levels of 
stringency. These retained measures are: 

M1  - Scope extension  
M2 - Requiring compatibility with USB-PD specifications to increase interoperability 
M3  - Minimum energy efficiency at 10% load 
M4 - Raising the minimum requirement on active average efficiency and limiting standby 

losses for wireless chargers 

M5 - Externalisation of power supply circuitries for battery charging devices and wireless 

chargers 

M6  - Durability 

The full description of these measures and their rationale are included in Annex 10. The  main 
reasons for addressing them in the policy options are: 

•  Scope extension is relevant to expand the benefits of the EPS regulation  to EPS that 

are not currently covered by it. 

• 

Interoperability is important to increase consumer convenience and reduce expenditure 
as part of the common charger initiative and to  reduce the environmental impacts  of 
EPS production through longer EPS lives. 

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•  Efficiency at 10% load is much lower than at higher output power levels. It is relevant 
since  a  significant  share  of  time  is  spent  at  low  load  and  this  may  increase  with 
interoperable EPS. 

•  Market data shows that there is energy savings potential from improving the efficiency 
of  the  worst  performing  EPS  on  the  market  as  well  as  addressing  wireless  charging 
standby losses.  

•  Externalisation  of  power  supply  circuitry  for  some  battery  and  wireless  chargers 
brings their power supply within the scope of the regulation and therefore extends its 
interoperability and efficiency benefits to these devices. 

•  Avoiding  premature  failure  of  EPS  will  reduce  the  environmental  impacts  of  their 

production and also bring consumer benefits. 

Table 3 illustrates how the set of retained measures are aimed at addressing all aspects of the 
review clause and the problem drivers. This annex also includes a preliminary assessment of 
the  impact  of  their  application  individually  that  enables  the  construction  of  a  logical  set  of 
policy options for analysis. 

Requirements in the review clause 

M1  M2  M3  M4  M5  M6 

x 

x 

x 
x 

x 
x 
x 
x 

transparency  and  untapped 

R1 Efficiency at 10% load 
R2 Addressing wireless charging  
R3 Addressing active power over ethernet 
R4 Addressing equipment not in Annex I 
R5 Circular economy and interoperability 
Problem Drivers 
D1 Limited scope 
D2  Lack  of 
potential 
D3 Lower efficiency at low load 
D4 Lacking interoperability 
D5  Lack  of  information  on  compatibility  with 
load 
D6 Bundling EPS with products 
D7 Scope and testing adaptive EPS 
D8 Requirements of standards and legislation 
D9 Wireless chargers and PoE 
Table 3 - Matrix showing how the different measures address the review clause aspects and problem drivers 

x 
x 

x 
x 

x 
x 

x 
x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

The available policy options focus on the achievement of the general and specific objectives 
through  the  application  of  measures  increasing  EPS  energy  efficiency  and  reducing  their 
environmental impacts without imposing significant burden to manufacturers or costs to end-
users, as set out in Article 15(5) of the Ecodesign Framework Directive. These policy options 
are  designed  with  increasing  stringency  in  different  dimensions  to  enable  a  comprehensive 
comparison. 

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5.1. The intervention logic 

Figure 6 - Intervention logic 

Figure  6  shows  the  overall  intervention  logic  and  the  links  between  drivers  (D),  problems, 
specific objectives (SO), and policy options (POs).  

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

The  updated  EU  Fit  For  55  MIX  scenario  (FF55  MIX)  provides  the  electricity  prices  and 
GHG  intensity  used  in  this  impact  assessment.  More  details  about  other  input  data  and 
analytical models are provided in Annex 4. FF55 MIX projects EU and Member States energy 
developments up to 2050, based on global and EU market trends at the time and incorporating 
the effect of the Fit For 55 proposal. 

Although  the  Commission  has  proposed  to  replace  the  Ecodesign  Directive  with  the  ESPR 
and  this  is  now  agreed  by  the  co-legislators,  the  effect  on  the  baseline  is  expected  to  be 
modest for a number of reasons. First, the new products in scope of the ESPR do not consume 
energy during their use, and therefore the increase in energy in its scope will primarily relate 
to  embedded  energy  (manufacture,  distribution  and  end-of-life  of  products).  Second,  the 
totality of the new products’ embedded energy is shared between EU and non-EU countries 
depending  on  the  split  of  production.  Third,  EU  producers  are  subject  to  ETS  pricing  and 
other regulatory measures that mean that they are likely to have less room for improvement 
compared to non-EU producers. Finally, the period to develop and adopt secondary legislation 
and for it to  come in force will mean that  substantial  impacts  could  not  be expected  on the 
short run.  

The amended RED requires making USB-PD a mandatory option for a broad range of battery 
powered radio equipment, and a mandatory unbundling option, i.e. that devices in scope have 
to  be offered  (also) without  an  EPS. These requirements are effective from  December 2024 
for most products and from April 2026 for laptops. This will have an effect on EPS design in 
terms of implementing the USB-PD specification and an expected reduction in new EPS sales 
due  to  unbundling.  These  consequences  of  the  RED  amendment  are  a  core  element  of  the 
baseline for the future EU EPS market. 

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While  the  EPS  disaggregation  and  sales  and  performance  figures  in  the  EIA  provide  an 
important  starting  point,  these  have  been  expanded  and  amended  in  light  of  information  on 
market and behavioural trends. Notable impacts arise due to roughly 10% lower losses based 
on  market  figures  and  significantly  lower  no-load  values  than  assumed  in  EIA.  The 
comprehensive DoE analysis of use patterns in relation to powered end-device use habits has 
also influenced the model assumptions about how many hours are operated at which load and 
these differ from those in the EIA. The new baseline assumptions are detailed in Annex 4. 

Figure 7 - Graphs showing evolution of EPS energy use (left) and GHG (right) under BAU 

The two graphs in Figure 7 illustrate how EPS energy use and the associated CO2 emissions 
are  expected  to  evolve  under  BAU.  The  black  solid  line  in  the  left  graph  shows  that  the 
energy  used  in  EPS  will  progressively  increase  in  absolute  terms  and  the  red  dashed  line 
shows that it will also increase as a share of total energy consumption. The black line in the 
right  graph  shows  that  EPS  related  CO2  emissions  will  progressively  decrease  under  BAU. 
However,  the  red  dashed  line  shows  that  CO2  emissions  due  to  EPS  will  decrease  less  as  a 
proportion over the period, driven by the increased share of energy used by them. 

5.3. The interactions between EPS efficiency, durability and interoperability 

Because  this  impact  assessment  explores  a  range  of  product  parameters  in  addition  to 
interoperability,  the  identification  of  their  optimal  combination  is  more  complex.  For 
example,  to  enable  the  interoperability  that  ensures  the  possible  longer  use  of  EPS  requires 
standardised  architecture,  connectors  and  cables  that  may  lead  to  some  efficiency  losses  or 
require additional energy use for their production. Figure 8 shows the main interactions. 

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On: 

Impact 
of: 

Interoperability 

Durability 

Energy used in 
production 

Interoperability  Durability 

Energy used 
in production 

Energy 
Efficiency  

By enabling EPS to be 
reused and therefore 
have longer lives, the 
issue of their 
durability becomes 
relevant. 

Interoperable EPS may 
be reused thus 
requiring less 
production and 
therefore less total 
energy use in 
production. 

Interoperability leads 
to longer life that 
enables payback. 

Interoperability may 
result in energy losses 
through PD system, 
connectors and cables. 

More durable EPS 
might require more 
energy to produce per 
EPS. 

Better durability 
enables longer 
payback of energy 
efficiency benefits. 

Longer EPS lives lead to 
greater consumer benefit 
from interoperable EPS. 

No identified relation. 

No identified relation. 

No identified relation. 

Energy 
Efficiency 

Cost savings from more 
efficient EPS over their 
longer life help offset 
additional cost of 
interoperable EPS. 

Higher energy 
efficiency leads to 
lower losses and 
therefore lower heat 
generation in EPS 
leading to longer life 
of components. 
Figure 8 - Interactions between interoperability, durability and energy 

More efficient EPS 
may require more 
energy to produce per 
EPS. 

These parameters are included in the assumptions in the model used to assess the impacts of 
the Policy Options (POs). 

5.4. Description of the policy options (POs) 

The measures retained for further analysis as described in Annex 10 are grouped into a set of 
POs. The aim is to explore the full range of combinations and understand their impacts and 
trade-offs. The two main dimensions are differing degrees of energy efficiency requirements 
and differing requirements relating to circularity. The POs are briefly described below: 

5.4.1.  Energy efficiency only (PO1) 

This  PO  focusses  only  on  energy  efficiency  of  EPS.  It  includes  the  introduction  of  an 
efficiency requirement at 10% load, increases no-load and active efficiency by a modest level 
of stringency and introduces a standby limit for wireless charging. 

5.4.2.  Interoperability, modest efficiency ambition (PO2) 

This PO includes requirements for interoperability and relevant information. It increases no-
load  and  active  efficiency  by  a  modest  level  of  stringency,  introduces  wireless  charging 
standby limits and requires externalisation of power supplies for single-cell battery charging 
applications. 

EN 

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5.4.3.  Interoperability, high efficiency ambition (PO3) 

This  PO  includes  requirements  for  interoperability  and  relevant  information.  It  increases 
active efficiency by a level of stringency met by 50% of current products, introduces wireless 
charging standby limits and requires externalisation of power supplies for  single-cell battery 
charging applications. 

5.4.4.  Interoperability, modest efficiency ambition with durability (PO4) 

This  PO  includes  requirements  for  interoperability  and  relevant  information.  It  increases 
active efficiency by a modest level of stringency, introduces wireless charging standby limits 
and  requires  externalisation  of  power  supplies  for  single-cell  battery  charging  applications. 
Durability requirements are introduced. 

5.4.5.  Interoperability, high efficiency ambition with durability (PO5) 

This  PO  includes  requirements  for  interoperability  and  relevant  information.  It  increases 
active efficiency by a level of stringency met by 50% of current products, introduces wireless 
charging standby limits and requires externalisation of power supplies for  single-cell battery 
charging applications. Durability requirements are introduced. 

5.4.6.  Interoperability,  10% 

load  and  modest  active  efficiency  ambition, 

externalisation and durability (PO6) 

This  PO  includes  requirements  for  interoperability  and  relevant  information.  It  introduces 
efficiency  requirements  at  10%  load,  increases  active  efficiency  by  a  modest  level  of 
stringency, introduces wireless charging standby limits and requires externalisation of power 
supplies for single-cell battery charging applications. Durability requirements are introduced. 

5.4.7.  Interoperability, 10% load and modest efficiency ambition with durability no 

externalisation (PO7) 

This PO is identical to PO6 but without requiring externalisation of power supplies for single-
cell battery charging applications. 

5.4.8.  Interoperability,  10% 

load  and  high  active  efficiency  ambition, 

externalisation and durability (PO8) 

This  PO  includes  requirements  for  interoperability  and  relevant  information.  It  introduces 
efficiency requirements at 10% load. It increases active efficiency by a level of stringency met 
by  50%  of  current  products,  introduces  wireless  charging  standby  limits  and  requires 
externalisation  of  power  supplies  for  single-cell  battery  charging  applications.  Durability 
requirements are introduced. 

EN 

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5.4.9.  Interoperability,  10% 

load  and  highest  active  efficiency  ambition, 

externalisation and durability (PO9) 

This  PO  includes  requirements  for  interoperability  and  relevant  information.  It  introduces 
efficiency requirements at 10% load. It increases active efficiency by a ‘best in market’ level 
of  stringency,  introduces  wireless  charging  standby  limits  and  requires  externalisation  of 
power  supplies  for  single-cell  battery  charging  applications.  Durability  requirements  are 
introduced. 

5.5. Policy Options matrix 

Table  4  below  illustrates  graphically  the  approach  followed  to  compose  the  POs  described 
above  from  the  measures  with  an  X  showing  that  a  measure  is  incorporated  in  the  relevant 
PO. 

Individual measures 

PO1  PO2  PO3  PO4  PO5  PO6  PO7  PO8  PO9 

Policy Options 

Interoperability and information 
(M2b) 

Efficiency requirement at 10% 
load for EPS > 10W (M3b) 

Active efficiency modest 
stringency (M4a) 

Active efficiency high stringency 
(M4b) 

Active efficiency ‘best in market’ 
stringency (M4c) 

Wireless charging standby limit 
(M4d) 

x 

Externalisation of power supply 
for wireless chargers and single 
cell battery chargers (M5) 

EPS durability requirements (M6) 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

Table 4 - Matrix showing which measures are included in the Policy Options 

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6.  WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? 

6.1. Business-as-Usual (BAU) 

Under BAU there will be no new action and the current Regulation stays in place without any 
revision. A major change in the market is triggered by the amended RED, requiring USB and 
USB-PD  compatibility  for  a  range  of  types  of  battery-powered  radio  equipment  from  2024 
and  2026  for  laptops  respectively  onwards.  This  also  includes  a  mandatory  requirement  to 
offer an option of purchasing products without an EPS (mandatory unbundling option).  

Compared to the BAU scenario estimated in the EIA there is a significant shift in the market 
from USB EPS in the 5-10W range to 20W and above to facilitate fast charging of batteries. 
This  scenario  provides  the  baseline  against  which  the  other  options  are  assessed  and  the 
expected change in the main indicators are shown in Table 5.  

Table 5 - BAU evolution of main indicators 

Under BAU, the Gross Energy Requirement (GER)34 for EPS in scope in 2040 is projected to 
increase by 21%. GHG emissions are projected to decrease by 70% compared to 2020, mainly 
due  to  changes  of  the  GHG  intensity  of  the  EU27  electricity  grid.  Acquisition  costs  (in 
constant Euros) are projected to increase by 8.7%, despite interoperability requirements under 
the  RED  while  total  electricity  costs  are  projected  to  increase  by  54%.  Total  user  costs  are 
expected  to  increase  by  17%,  mainly  due  to  the  growing  market  for  wireless  chargers.  The 
manufacturing  revenue  from  EPSs  is  projected  to  decrease  due  to  increased  competition,  as 
shown by the purchase costs in 2030 compared to 2025, once EPS for RED equipment can be 
used interchangeably from various vendors. 

6.2. Economic impacts of the POs 

6.2.1.  Annual economic impacts over 2020-40 

Figure 9 shows the modelled changes in annual consumer expenditure over the period 2020 to 
2040 for the range of POs. The main outlier is PO1 that fairly closely follows BAU, both with 
a reduced expenditure in 2030 as a consequence of the reduced EPS purchases flowing from 
the RED. For all the other POs, the additional requirements initially lead to higher consumer 
costs before they reduce to below BAU after 2030. Figure 10 shows how the annual consumer 
expenditure changes compared to BAU for each PO over the period. As already seen, PO1 is 
the main outlier in 2030 while in 2035 and 2040 it is PO2 and PO3 that differ significantly 

34 Gross Energy Requirement (GER) is the primary energy used in all stages of the product-life. 

EN 

33 

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BAUSocietal Life Cycle Costs (€m)Annual consumer expenditure (€m)thereof purchase price (€m)thereof electricity totals (€m)Greenhouse Gases (Mt CO2eq)Total Energy (PJ)Total weight (kt)Acidification (kt SO2eq)Particulate Matter (kt)202069936503532411792.069.229.83.770.80202575377056571313431.973.233.94.070.92203073306998516718311.275.431.83.650.82203579357666571119550.883.234.93.820.87204078387608578718210.684.035.73.850.89 
 
 
from the other POs. The latter two POs differ from the others in not including requirements on 
durability or efficiency at 10% load. 

Figure 9 - Change in annual consumer expenditure 

Figure 10 - Change in annual consumer expenditure due to POs compared to BAU 

As can be seen from the figures for 2035 and 2040, because of the relatively short life of non-
interoperable EPS, once the replacement of the EPS stock has taken place the cost stabilises at 
a lower cost than BAU due to a lower rate of EPS purchases. 

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6.2.2.  Annual economic impacts in 2035 

Table 6 below shows the estimated economic impacts of the POs for 2035. All POs lead to a 
reduction of annual electricity use, although the reduction ranges from €16mln to €182mln. 

The  impacts  on  purchase  cost  are  more  varied,  from  a  €117mln  increase  to  an  €86mln 
decrease.  The  PO  with  only  energy  efficiency  requirements  (PO1),  as  well  as  those  with 
interoperability  but  without  durability  requirements  (PO2&3),  and  that  with  the  highest 
energy efficiency ambition (PO9), all show an increase in purchase costs. This is  due to the 
additional  cost  of  the  changes  to  meet  the  higher  energy  efficiency  requirements,  while  the 
reduction of EPS purchases to offset this increase through longer EPS lifetimes is too limited 
(PO2, 3, 9) or none (PO1). 

Table 6 - Main annual economic impacts of the Policy Options in 2035 

The  impact  on  total  annual  consumer  expenditure  ranges  from  an  overall  increase  of  €10m 
(PO3) to a saving of €143m (PO1). 

6.2.3.  Cumulative cost impacts 

Except for PO1, it has been shown that all POs lead to a significant increase in purchase costs 
in  the  first  few  years  of  implementation.  While  a  small  part  of  the  price  increase  is  due  to 
more stringent energy efficiency requirements, the majority of the cost increase is due to the 
implementation of interoperability requirements. 

To  estimate  the  cumulative  cost  changes  over  time,  the  annual  cost  changes  vs  BAU  are 
interpolated  for  both  electricity  and  purchase  costs  and  the  results  summed  over  5-year 
periods.  The  only  exception  to  this  is  the  change  in  purchase  costs  for  POs  including 
interoperability where it  is  assumed that the increased purchase cost in  2030 already comes 
into effect from 2026 onwards to cover the assumed average life of existing non-interoperable 
EPS  that  are  being  replaced  with  interoperable  ones.  Once  they  are  replaced,  the  assumed 
longer life leads to lower annual purchases and therefore lower annual purchase costs. 

EN 

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 EU27 annual impact  Policy option 7666057110195507522-1435750391773-1827655-11571651939-167675105763531912-437564-1015625-861939-167584-825672-391912-437565-1015643-681922-337572-945650-601922-337579-875692-191887-687630-3658271171802-152Change in total consumer cost (€m)Change in purchase cost (€m)PO6PO5PO4PO3PO2PO1PO9PO7PO8BAUTotal consumer expenditure                         (€m)Purchase price in total consumer expenditure (€m)Change in electricity cost (€m)Electricity cost in total consumer expenditure (€m) 
 
Figure 11 Five-yearly cumulated consumer cost change vs BAU and sum over 2025-45 

The cumulated consumer cost change over the period 2025 to 2045 is shown at the right of 
Figure 11. This varies from a decrease of over €2bn for PO1 to an increase of over €2bn for 
PO3.  Of  the  POs  including  interoperability,  PO4  performs  best  with  a  cumulative  cost 
increase of €156mln and PO6 is the next best with a cost increase of €196mln. 

These cost figures only cover the purchase and electricity costs. They do not take account of 
the  value  of  interoperability  to  consumers.  The  value  of  this  interoperability  is  uncertain, 
although  anecdotally  it  is  considerable.  The  estimates  in  Annex  15  show  that  consumer 
convenience  from  interoperable  EPS  may  have  a  value  around  €250mln  per  year  with 
indicatively  a  low  estimate  of  €123mln  and  a  high  of  €370mln  per  year.  The  20-year 
cumulative  cost  increase  of  POs  including  interoperability  varies  between  an  increase  of 
€8mln  and  €109mln  per  year  indicating  that  the  benefits  in  terms  of  increased  consumer 
convenience comfortably offset the additional costs over 20 years.  

If a shorter time period is considered, the annualised cumulative cost increase rises to between 
€45mln and €141mln over 15 years or €118mln to €207mln for 10 years. Even in these cases 
the  range  for  all  the  POs  is  comfortably  less  than  the  estimated  increase  in  consumer 
convenience. 

6.3. Environmental impacts of the options 

Table 7 below shows the estimated environmental impacts of the options  for 2035. All POs 
lead to a reduction of GER. The best performing achieve around an 8% reduction (PO9&1). 
The worst performers achieve around a 2% reduction (PO2&4) while the rest achieve around 
a 3 to 4% reduction. 

The performance in terms of GHG emission reductions is quite different. The worst performer 
by far achieves only around 3% saving (PO1) while all the rest achieve between 7 and 10% 
saving  because  they  include  interoperability  requirements  and  therefore  lead  to  lower  EPS 
purchases.  For  POs  including  interoperability,  the  GHG  savings  increase  with  energy 
efficiency  stringency  and  so  the  best  performer  (PO9)  is  that  with  the  highest  energy 
efficiency ambition while pairs of options with equal  requirements other than the efficiency 

EN 

36 

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level  show the greater GHG savings with  the higher ambition  (PO8 compared to  PO6, PO5 
compared to PO4 and PO3 compared to PO2).  

In  terms  of  the  changes  to  acidification  and  PM  emissions  the  impacts  of  the  various  POs 
have  a  comparable  pattern.  Most  of  the  POs  (PO4,  5,  6,  8  &  9)  have  a  largely  comparable 
impact.  For  acidification  PO8&9  deliver  slightly  higher  benefits,  PO7  has  slightly  lower 
benefits while PO2&3 are somewhat worse and PO1 has virtually no benefits for acidification 
and PM emissions since it mainly  affects  use of electricity in  the EU which has  a  very low 
pollutant emission intensity. 

Table 7 - Main environmental impacts of the Policy Options 

The impacts of the various POs on absolute GHG emissions over time are shown in Figure 12.  

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37 

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 EU27 annual impact  Measure 83.220.00.820.0003.820.0000.870.00076.46-6.80.79-0.0223.80-0.0240.87-0.00181.62-1.60.76-0.0593.37-0.4500.78-0.08780.62-2.60.75-0.0623.37-0.4540.78-0.08781.42-1.80.74-0.0703.31-0.5160.76-0.10680.42-2.80.74-0.0733.30-0.5200.76-0.10680.77-2.50.74-0.0723.30-0.5190.76-0.10680.82-2.40.75-0.0703.32-0.5030.77-0.10179.45-3.80.74-0.0773.30-0.5230.76-0.10676.34-6.90.73-0.0873.29-0.5340.76-0.106BAUPO1PO2PO3Change in GHG emissionsPO4PO5PO7PO8PO9Gross Energy Requirement (PJ)Acidification emissions          (kt SO2eq.)Particulate Matter (PM, dust) (kt)PO6Change in acidification emissionsChange in PM emissionsChange in Gross Energy Requirement (PJ)Greenhouse Gases         (Mt CO2eq.) 
 
Figure 12 - Total annual EU27 GHG emissions of POs, 2020-2040 

This  illustrates  that  the  differences  between  the  POs  are  small  and  they  all  have  a  similar 
reduction profile. The main driver of GHG reduction is the decarbonisation of the electricity 
supply as shown by the reduction in BAU.  

Figure 13 shows more clearly the differences between the GHG savings of the different POs 
compared to BAU. In general, these show increasing GHG savings moving from PO2 to PO9. 
In  2030  there  is  some  divergence  from  this  trend,  probably  due  to  the  still  ongoing 
replacement  of  less  efficient  non-interoperable  EPS  at  that  point  which  will  be  largely 
complete by 2035. 

Figure 13 - Changes to total annual EU27 GHG emissions of POs vs BAU, 2030-2040 

It  can  be  noted  that  PO1  results  in  no  GHG  emission  savings  in  2040  since  it  only  affects 
electricity consumption and not EPS sales. This is also true in relation to the electricity use for 
all other POs  due to the assumed decarbonisation of EU electricity production by then. The 
GHG  savings  for  the  other  POs  in  2040  result  exclusively  from  the  reduced  production 
emissions. 

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6.4. Social impacts 

Two main types of social impact are considered. Firstly, it is assessed whether the POs lead to 
affordability issues as required in Article 15(5)c of the Ecodesign Directive that requires that 
“there  shall  be  no  significant  negative  impact  on  consumers  in  particular  as  regards  the 
affordability  and  the  life  cycle  cost  of  the  product”.  The  assumptions  detailed  in  Annex  4 
show  the  cost  of  the  interoperability  and  energy  efficiency  requirements  costs  for  affected 
EPS. The modelling shows for the year 2030 that  the cost  per EPS will increase between 1 
and 12% with a 7% overall price increase. The largest percentage increase is for the smallest, 
lowest  cost  EPS.  These  levels  of  cost  increase  for  relatively  low-cost  products  should  not 
affect affordability. 

Changes in employment in the EU are assessed in a simple manner based on the employment 
intensity of relevant sectors described in Annex 4. The main impacts result from the change in 
retail  sector  turnover  (estimated  at  0.3  times  the  change  in  purchase  cost),  the  change  in 
electricity  sector  employment  (resulting  from  reduced  electricity  use)  and  the  change  in  the 
general economy as a result of the net increase or decrease in expenditure on EPS. The results 
for the POs are shown in Table 8 and can be seen to be overall positive but insignificant. 

Table 8 - Estimated employment impacts of the POs 

6.5. Impact on societal costs 

Table  9  shows  how  the  inclusion  of  certain  monetised  externalities  affects  the  purely 
consumer view of costs shown in section 6.2. The overall societal benefits are greater in all 
cases and the overall ranking of the impacts of the POs doesn’t change significantly although 
some  options  appear  slightly  more  attractive  than  from  a  purely  consumer  cost  perspective. 
The  societal  costs  include  air  pollution  emissions  which  occur  largely  outside  the  EU  and 

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 EU27 impact  Policy option 000000039-1821245-1277156335-1616-11605553-431661-30113144-86-16-26-100-1117463-39-43-12-46-30228153-68-33-20-79-23225123-60-33-18-71-23215121-19-68-6-22-47309239117-15235137-107493523PO9Assumed change in retail turnover (€m)Estimated retail sector employment impactChange in purchase cost (€m)Change in electricity cost (€m)BAUPO1PO2Estimated net impact on EU employmentEstimated electricity sector employment impactEstiamted general economy employment impactPO3PO4PO5PO6PO7PO8 
 
whose societal impact will then largely be experienced outside the EU. In contrast the GHG 
emissions have a global impact. 

Table 9 - Impact of POs on societal lifecycle costs in 2035 

The  most  substantial  change  compared  to  the  ranking  from  a  consumer  expenditure 
perspective is that the ranking of PO4 and PO6 change places (they rank 2nd and 3rd highest 
savings) with PO6 having a better ranking from the societal viewpoint. The other significant 
change is  that PO3 which ranks worst from both  perspectives, leads to  a  net  benefit from  a 
societal  point  of  view  while  it  leads  to  a  net  increase  in  cost  from  the  purely  consumer 
expenditure point of view. 

6.6. Overview of the PO impacts 

All  the  key  impacts  of  the  POs  in  2035  are  illustrated  by  the  radar-plot  in  Figure  14.  This 
shows  the  contribution  of  each  option  to  the  assessed  parameters  within  the  range  of  0 
(smallest)  and  1  (largest)  saving.  This  helps  to  understand  the  difference  in  contribution  of 
each  PO  for  each  parameter,  although  it  exaggerates  the  difference  between  them  and 
therefore  has  a  limited  value  in  comparing  the  overall  performance  of  the  POs  for  all  the 
different parameters.  

Figure 14 - Impacts of combined options 

The  most  striking  divergences  are  for  PO1  and  PO9.  In  contrast,  PO2  to  7  have  relatively 
similar profiles but vary in the scale of benefit achieved. 

In the case of PO1, because it does not contain any interoperability measures it has no impact 
on e-waste and virtually no impact on PM and acidification emissions and the least impact on 
GHG emissions. It delivers high consumer cost and GER savings because it does not include 
the interoperability requirements that add cost and manufacturing effort. 

EN 

40 

  EN 

Policy OptionBAUPO1PO2PO3PO4PO5PO6PO7PO8PO9Societal Life Cycle Costs (€m)7935778779007920780578247805781478187867 
 
 
PO9  differs  from  the  bulk  of  the  other  POs  because  it  contains  the  most  stringent  energy 
efficiency  requirement.  This  leads  also  to  high  energy  and  GHG  savings  but  with  negative 
impacts on purchase price and therefore performs poorly on consumer cost savings. 

7.  HOW DO THE OPTIONS COMPARE? 

7.1. How the options are compared 

The  intervention  has  two  specific  objectives.  The  first  is  to  reduce  lifecycle  energy 
consumption  of  EPS  to  the  level  leading  to  the  minimum  lifecycle  cost  to  consumers.  The 
second  is  to  reduce  the  other  environmental  impacts  of  EPS.  To  compare  the  options  it  is 
therefore necessary to determine how adequately each PO: 

•  Sets  energy  efficiency  requirements  at  the  level  that  achieve  the  lifecycle  cost 

minimum for consumers; 
Is  effective  in  achieving  the  specific  objectives,  i.e.  the  degree  to  which  it  leads  to 
energy savings and reduced environmental impacts; 
Is efficient in achieving the specific objectives i.e. how cost efficiently the objectives 
are achieved; 
Is coherent with other EU policy objectives. 

• 

• 

• 

Based on a ranking of each PO against these four elements the comparison can be made and 
the best performing option selected. 

7.2. Determining the end-user lifecycle cost minimum level of EPS efficiency  

The Ecodesign Directive requires that “the level of energy efficiency or consumption must be 
set  aiming  at  the  life  cycle  cost  minimum  to  end-users  for  representative  product  models, 
taking into account the consequences on other environmental aspects”. 

Because  of  the  complex  interaction  of  the  energy  efficiency  requirements  and  the 
interoperability  requirements  and  the  costs  related  to  them  it  is  important  to  distinguish  the 
two effects to ensure that energy efficiency is set at the lifecycle cost minimum. 

EN 

41 

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Figure 15 - EPS life cycle cost curve for energy efficiency measures 

As a first step, the cost impacts of different energy efficiency measures and combinations are 
compared to enable a life cycle cost curve to be established. This requires including in a cost 
curve the different possible measures to address active, 10% load and no-load efficiency. This 
uses the impact of the efficiency measures on the EPS market as assessed in Annex 10. Figure 
15 shows two curves, the first dashed line is based on BAU assumptions about EPS lifetime 
and  the  second  solid  line  where  a  50%  longer  EPS  lifetime  is  assumed  in  line  with  the 
expectations  on  the  effect  of  interoperability.  The  horizontal  axis  of  the  graph  shows 
incremental increases in the application of energy efficiency measures while the vertical axis 
shows  the  lifecycle  consumer  cost  resulting  from  the  additional  purchase  costs  due  to  the 
efficiency measures and the discounted electricity costs savings. 

The parts of the cost curves under the x-axis are those where the measures lead to a reduction 
in  lifecycle  consumer  cost.  The  dashed  line  in  the  graph  shows  that  without  any  lifetime 
extension the lowest lifecycle cost is achieved with measure M4a alone or coupled with M3a. 
There is uncertainty in the assumptions and the calculations and so it might be reasonable to 
think that any of the options  from  M4a only  to  M4a+M3b could  also  be acceptable  as they 
show lower LCC. 

The effect of a 50% longer EPS life is shown in the solid line where the consumer benefit is 
greater due to the longer period in which the energy savings materialise.  The life cycle cost 
savings  of  the  efficiency  measures  are  greater  and  the  range  of  possible  combinations  of 
measures  that  lead  to  a  life  cycle  cost  savings  for  consumers  is  slightly  broader  than  in  the 
BAU case including M4b+M3b. The lowest LCC appears to be M4a+M3b. 

7.3. Effectiveness and efficiency of options 

Figure 16 below on the left shows how effective the various POs are at achieving the Specific 
Objectives, with the most effective counting as 1 and all others shown as a proportion of that. 
The results are shown for the central scenario where the weight of the contribution to SO1 and 
SO2 is equal. A range of sensitivity tests (see Annex 13) with a 6:4 and 7:3 ratio and one with 
a  9:1  ratio  do  not  significantly  alter  the  overall  effectiveness  rankings.  In  all  cases  PO9  is 
shown  as  the  most  effective.  In  most  cases  the  worst  performers  are  PO1  and  PO2.  PO3 to 
PO8 are relatively closely ranked and generally PO8 and PO5 perform slightly better although 

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the  ranking  changes  with  the  sensitivity.  Only  if  a  very  high  emphasis  is  placed  on  SO1 
(energy) does PO1 approach the ranking of PO9. 

Figure 16 - Normalised ranking of effectiveness (left) and efficiency (right) of policy options 

In contrast the right part of Figure 16 shows the cost efficiency of the POs with a 3% discount 
rate. In this case PO1 is the highest scoring and remains so for almost all sensitivity tests other 
than with a 90% weighting for SO1. The second-best scoring are PO4 and PO6 and remain so 
for all the sensitivity tests. With an extreme weight on energy, PO4 becomes the best scoring. 

7.4. Scoring the options 

Based on the analysis presented the different options can be scored. The approach followed is 
described below: 

• 

• 

In  relation  to  Life  Cycle  Consumer  Cost,  1  point  is  given  for  POs  containing 
combinations of measures that lead to consumer cost savings and 2 points to options 
including the combination of measures with the Lowest Life Cycle Consumer Cost.  
In  relation  to  Effectiveness  and  Efficiency,  1  point  is  allocated  for  a  score  in  the 
bottom third of the marks, 2 points if it is in the middle third and 3 points if it is the 
highest third as shown in Figure 17 below.  

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POCENTRALPO10.49PO20.60PO30.66PO40.68PO50.75PO60.72PO70.70PO80.81PO91.00POCENTRALPO11.00PO20.26PO30.17PO40.52PO50.43PO60.50PO70.49PO80.43PO90.26POPO1PO2PO3PO4PO5PO6PO7PO8PO9CENTRAL0.4920.5990.6610.6830.7460.7240.7040.8061.000Score111222223 
 
 
Figure 17 - Scoring matrix for effectiveness (top) and efficiency (3%NPV) (bottom) 

•  For  Coherence,  all  measures  have  been  assessed  to  ensure  they  are  coherent  with 
policy  objectives  and  therefore  the  POs  combining  them  are  also  coherent.  A 
distinction  that  can  be  made  between  them  relates  to  the  degree  to  which  the  POs 
contribute  to  the  Circular  Economy  through  enabling  EPS  reuse  or  prolonging  their 
operating lives. The options are allocated 1 point each if they include interoperability 
requirements and 1 point if they include durability requirements.  

7.5. Ranking the options 

The scoring described in section 7.4 is applied to the POs as shown in Table 10. 

PO 
PO1 
PO2 
PO3 
PO4 
PO5 
PO6 
PO7 
PO8 
PO9 

LCCC 
2 
1 
0 
1 
0 
2 
1 
1 
0 

Effectiveness  Efficiency  Coherence  Total 

1 
1 
1 
2 
2 
2 
2 
2 
3 

3 
1 
1 
2 
1 
2 
2 
1 
1 

0 
1 
1 
2 
2 
2 
2 
2 
2 

6 
4 
3 
7 
5 
8 
7 
6 
6 

Table 10 - Ranking of the Policy Options 

Based  upon  the  scoring,  PO6  (shown  in  grey)  appears  the  most  desirable  as  the  only  PO 
scoring 8 points. Next best are PO4 and PO7, with 7 points, that only differ from PO6 in not 
including M4.3 in the case of PO4 and a higher level of active efficiency (M4b) in PO7. Next, 
PO1, 8 and 9 all score 6 points. 

A  wide  range  of  sensitivity  tests  have  been  performed,  described  in  Annex  13,  varying  the 
share of SO1 and SO2 in assessing effectiveness, the importance of LLCC, the discount rate 
and to check results against societal costs. The results are robust with PO6 nearly always the 
preferred option. 

8.  PREFERRED OPTION 

8.1. Legal requirements 

Annex  II  of  the  Ecodesign  Directive  states  that  “the  level  of  energy  efficiency  must  be  set 
aiming at the lifecycle cost minimum to end-users”. It goes on to say “taking into account the 
consequences  on  other  environmental  aspects”.  This  has  been  assessed  in  section  8,  and 
specifically  8.2  to  identify  the  optimal  PO  taking  account  of  the  lowest  lifecycle  consumer 
cost. The consequences on other environmental aspects are addressed in section 9.3 below.  

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POPO1PO2PO3PO4PO5PO6PO7PO8PO9CENTRAL1.0000.2590.1690.5220.4330.5000.4910.4250.260Score311212211 
 
The Directive also  sets  a series of requirements  in  its Article 15(5) on  functionality,  health, 
technology  and 
safety  and  environment,  affordability,  competitiveness,  proprietary 
administrative burden. It is considered that all the POs satisfy these since measures that fail to 
satisfy these requirements have been discarded  and affordability at  the level  of the POs has 
been assessed. 

8.2. Main impacts 

PO6  brings  together  requirements  on  interoperability,  durability  with  energy  efficiency 
requirements on active, 10% load and no load as well as requirements on wireless charging. 
Under the preferred option, a further 35-40 % of EPS placed on the EU market are anticipated 
to be required to become interoperable, in addition to those powering RED devices. The main 
expected impacts in 2035 of the preferred option are shown in Table 11 below. 

Table 11- Main energy and environmental impacts of the preferred option in 2035 

Many of the environmental benefits are a result of reduced material use in the EPS or as fuel 
combusted to supply electricity. The impacts on these material uses are shown in Table 12. 

Table 12 - Impacts of the preferred option on material use in 2035 

8.3. Verifying the missed environmental benefits of other options 

In  determining  the  appropriate  level  of  energy  efficiency  ambition,  the  Ecodesign  Directive 
requires that account should be taken of “the consequences on other environmental aspects” 
of the choice of stringency. To assess these consequences, the approach followed has been to 
calculate  the  monetized  value  of  the  difference  in  environmental  impacts  between  the 
preferred option and the other options based on standard valuations of these externalities.  

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Total Energy (GER), in PJChange as % of BAUAbsolute GHG emissions (Mt CO2eq.)Change as % of BAUAbsolute acidification emissions (kt SO2eq)Change as % of BAUParticulate Matter    (kt PM)Change as % of BAUBAU83.680.8273.860.88PO680.77-3.5%0.743-10.1%3.30-14.4%0.76-13.1%Absolute new EPS weight (e-waste) (kt)Change as % of BAUFuel combusted (Mt)Change as % of BAUBAU35.202.74PO630.21-14.2%2.67-2.4% 
 
 
All impacts on material or energy use are assumed to be internalised in prices. The extra value 
of the environmental impacts in €mln compared to those of the preferred option is shown in 
the  left  column  of  Table  13.  Where  the  figure  is  negative  the  environmental  benefit  of  the 
option  is  greater  than  those  of  the  preferred  option  and  its  cost  effectiveness  is  therefore 
assessed. The middle column of Table 13 shows the additional consumer cost of that option in 
€m compared to the preferred option.  

It should be noted that while GHG emissions have an impact at global level and therefore are 
relevant to the EU wherever they occur, the same is not true of the other pollutant emissions 
included  in  the  assessment.  In  view  of  this,  the  net  environmental  value  calculated  will  be 
larger  than  the  impacts  expected  in  the  EU  from  the  emissions,  since  a  large  part  of  the 
pollutant emissions are emitted in countries where EPS are manufactured, primarily in Asia. 

PO 

Net environmental 
value vs preferred 
option (€m) 

Additional 
consumer cost vs 
preferred option 
(€m) 

Multiple of 
consumer cost to 
extra environmental 
benefit 

PO1 
PO2 
PO3 
PO4 
PO5 
PO6 
PO7 
PO8 
PO9 

19.7 
3.5 
3.1 
0.3 
-0.1 
0.0 
0.8 
-0.5 
-1.8 

-35 
90 
111 
0 
19 
0 
7 
14 
47 

N/A 
N/A 
N/A 
N/A 
190 

N/A 
28 
26 

Table 13 - comparison of costs and environmental impacts of other POs compared to the preferred option. 

This check is most relevant for the policy options that have an overall ranking close to that of 
the preferred option which are the rows shown in grey in the table. As can be seen, only three 
of these POs have a better environmental performance than the preferred option  (PO5, 8, 9) 
and are therefore of relevance. These are all among the POs with a scoring close to that of the 
preferred  option.  The  right-hand  column  shows  that  for  these  three  POs,  the  additional 
consumer cost is between twenty-six and one hundred and ninety times the monetized value 
of  the  additional  environmental  benefits.  Based  on  this  assessment  it  can  be  concluded  that 
there  is  not  sufficient  environmental  benefit  to  deviate  from  the  choice  of  the  energy 
efficiency level corresponding to the lowest lifecycle consumer costs 

8.4. Impact of consumer rate of reuse of EPS on the Preferred Option 

A key uncertainty in the analysis is the degree to which consumers will take advantage of the 
opportunities offered by interoperable EPS to avoid purchasing new EPS with new devices. In 
the optimal case, consumers would be assumed to continue using an EPS until it reaches the 
end  of  its  technical  life.  Provided  the  EPS  is  sufficiently  powerful  for  the  end  device,  this 
could reasonably be expected to lead to around a doubling of EPS lives. 

The  central  assumption  used  in  this  Impact  Assessment  is  that  EPS  lives  will  in  fact  be 
prolonged  on  average  by  1.5  times.  This  is  less  than  would  happen  in  the  optimal  case 
because  it  is  assumed  that  some  manufacturers  will  continue  to  supply  an  EPS  as  standard 

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with new end devices. In addition, some consumers will buy new EPS in any case, even if not 
needed.  

Table 14 - Comparison of main impacts with impact of sensitivity tests for consumer behaviour 

To test how crucial this assumed 50% average increase in product lives is, Annex 13 shows 
the effect of varying it and the results are summarised in Table 14 above. As expected, greater 
reuse  leads  to  bigger  savings  and  vice  versa.  Even  in  the  most  pessimistic  scenario  the 
preferred option brings energy and environmental benefits, but at the level of direct consumer 
cost it no longer looks positive. 

However,  these  figures  take  no  account  of  the  expected  greater  consumer  convenience, 
discussed  in  Annex  15.  The  absolute  value  of  this  increased  convenience  is  extremely 
uncertain,  however  from  the  assessment  it  appears  to  be  of  a  similar  magnitude  to  the 
increased cost in the worst case with only a 25% increase in EPS lives. This implies that even 
down  to  a  relatively  low  assumed  EPS  reuse  rate,  the  overall  impacts  including  greater 
consumer convenience should remain positive. 

8.5. REFIT 

The  proposed  policy  option  is  in  line  with  the  REFIT  objectives  of  simplification  and 
reduction of red tape. No net reporting or administrative requirements are created. 

The  requirements  largely  relate  to  compliance  with  existing  voluntary  industry  standards 
(USB-C and USB-PD) and align with the requirements in the RED. 

8.6. One-In One-Out 

The administrative costs as compared to the baseline are evaluated in Annex 3. They consist 
of additional labelling costs for printing of the Common Charger logo on the nameplate and 
the  product  package,  and  marking  of  the  Type-C  ports  on  the  enclosure  of  USB  power 
supplies, and are estimated to be very limited, i.e. in the sub-cent range up to €0.001 per EPS 
sold, which amounts to around €400k per year for all EPS placed on the EU market. 

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Total consumer expenditure (€m)Gross Energy Requirement (PJ)Greenhouse Gases (Mt CO2eq.)Absolute new EPS weight  (EoL e-waste) (kt)Fuel combusted (Mt)Acidification emissions (kt SO2eq.)Particulate Matter (PM, dust) (kt)Societal Life Cycle Costs (€m)BAU803184.20.8737.742.734.110.968320Reduction-26920.053.370.050.370.08-247Benefit-3%3%6%9%2%9%8%-3%BAU766683.20.8234.862.723.820.877935Reduction10120.074.650.050.520.11130Benefit1%3%9%13%2%14%12%2%BAU760883.10.8134.572.723.790.867875Reduction48930.116.970.060.760.17533Benefit6%4%14%20%2%20%20%7%Sensitivity 1.75Central 1.5Sensitivity 1.25 
 
8.7. Concluding remarks 

The preferred option (PO6) entails the following measures: 

•  Extension  of  the  scope  of  the  regulation  to  wireless  chargers,  single-cell  battery 

charging devices, active PoE injectors and stand-alone USB EPS. 

•  USB/USB-PD requirements for EPS with an output power below 240W. Exemptions 

apply.  

• 

Information  requirements  on  interoperability  for  USB  EPS,  including  a  Common 
Charger EU logo. 

•  Minimum efficiency requirement at 10% load operation for EPS > 10W. 

•  More stringent active average efficiency and no-load requirements. 

•  Stand-by power consumption limit for wireless charging pads. 

•  Externalisation of power supply circuitry for wireless chargers and single-cell battery 

chargers. 

•  Durability requirements. 

The anticipated impacts of the preferred option in 2035 are shown in Table 15: 

Table 15 - Impacts of the preferred option in 2035 

The  preferred  option  will  lead  to  around  an  additional  35  to  40%  of  the  EU  EPS  market 
becoming interoperable on top of the approximately 50% that are currently assumed to be as a 
result of the Radio Equipment Directive requirements. 

Ecodesign  requirements  make  an  important  contribution  to  the  EU’s  long-term  energy  and 
climate  objectives.  The  preferred  option  contributes  to  achieving  those  objectives  and  to 
achieving the goals of the EU Climate Law. 

Significant environmental impacts have been assessed and the analysis shows that the largest 
ones are associated with the consumption of energy in the use phase. These are reduced, while 
in line with the ‘do-no-significant-harm’ principle no other identifiable significant impacts are 
caused by the preferred option.   

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9.  HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED? 

An  analysis  of  the  products  on  the  market  (sales  figures  derived  from  generally  available 
market statistics, performance, etc.) can determine if the shift towards more resource efficient 
products  has  happened  as  intended.  The  requirement  to  publish  information  on  energy 
efficiency and no-load losses, and standby power consumption in  case of wireless chargers, 
allows  to  track  performance  in  terms  of  energy  related  requirements  over  time.  As  this 
information  however  is  not  maintained  centrally,  this  observation  of  market  developments 
requires additional research on the manufacturers’ websites.  

In  particular  monitoring  and  evaluation  should  be  based  on  the  following  indicators,  which 
reflect the general and specific objectives: 

1.  Market  penetration  (e.g.  percentage of sales for improved products  or  elimination of 
worst  performing  products,  products  sold  unbundled)  (Source:  Market  data,  WEEE 
registers); 

2.  Overall decline in sales as an indicator of longer product life cycles (Source: Market 

data); 

3.  Speed  with  which  market  penetration  of  improved  products  has  occurred,  i.e.  x 

number of years for y% penetration (source: Market data, manufacturer data); 

4.  Reduction of the related GHG emissions (To be estimated, based on sales of EPS and 

declared energy efficiency and energy consumption values); 

5.  Savings (economic) for European consumers (To be estimated based on product, EPS 

and electricity price trends); 

An evaluation of the initiative could usefully take place (indicatively) 5 years after entry into 
force  of  the  measures,  in  particular  as  regards  the  level  of  voluntary  unbundling.  The 
evaluation would build on the information from the above indicators.  

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Annexes 

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50 

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ANNEX 1: PROCEDURAL INFORMATION 

1.  Lead DG, Decide Planning/CWP references 

DG ENER, PLAN/2021/11755, Commission Ecodesign and Energy Labelling Working Plan 
2022-2024 (C/2022/2026). 

2.  Organisation and timing 

The  revision  of  the  Ecodesign  Regulation  on  external  power  supplies  is  included  in  the 
Ecodesign and Energy Labelling Working Plan 2022-2024. 

According  to  Article  7  of  the  Ecodesign  regulation  it  should  be  reviewed  in  the  light  of 
technological progress by 14 November 2022. A Call for Evidence was published on 4 April 
2022. 

A draft of the impact assessment report was submitted on 18 July 2023 to the members of the 
Ecodesign  and  Energy  Labelling  Interservice  Steering  Group,  involving  the  following  DGs: 
SG,  AGRI,  BUDG,  CLIMA,  CNECT,  COMM,  COMP,  DEFIS,  EAC,  ECFIN,  ECHO, 
EMPL,  ENV,  ESTAT,  FISMA,  GROW,  JRC,  JUST,  IDEA,  MOVE,  REFORM,  REGIO, 
RTD,  SANTE,  SJ,  TAXUD.  A  meeting  took  place  on  25  July.  Questions  were  raised  by 
JUST, EMPL and TAXUD, and were addressed by ENER. Written comments were received 
from DG ENV.  

3.  Consultation of the RSB 

The  draft  Impact  Assessment  was  submitted  to  the  RSB  on  27  September  2023.  A  meeting 
was  held  on  25  October  2023.  Following  the  negative  opinion  of  the  RSB  the  IA  has  been 
amended and was resubmitted on 7 March 2024. An overview of the improvements made in 
response to the RSB comments is set out below: 

(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. 

Amendments made to the IA in response  

A  new  section  1.1  has  been  added  that  explains  the  Ecodesign  Directive  and  the  need  for 
regular  reviews  of  measures  to  take  account  of  progress.  This  framework  requires  an 
exploration of what is feasible in the light of the consumer cost constraint. It is not possible to 
say up-front what can be achieved. 

A new section 1.7 has  been included to  explain the interaction with  the RED and how EPS 
information requirements can support consumers in identifying EPS for their RED devices. 

The description of the interoperability problem driver has been enhanced including in relation 
to the RED.  

The  description  of  the  scope  problem  driver  has  been  enhanced  to  explain  that  expanding 
scope enables setting energy efficiency and interoperability requirements that themselves can 
bring energy and environmental benefits. 

(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 

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cycle consumer cost. 

Amendments made to the IA in response 

 The  Ecodesign  Directive  aims  to  increase  energy  efficiency  and  protection  of  the 
environment  (while  ensuring  free  movement  of  products)  and  also  to  increase  security  of 
energy supply. These provide the objectives for the implementing measures adopted under it. 
The  specific  objectives  have  been  amended  to  separate  the  energy  and  the  environmental 
aspects and include the lowest life cycle consumer cost aspect. 

 The description of the measures and discarded measures have been moved to annexes 10 and 
11. This enables more detailed descriptions of the measures and explanations of the reasons 
behind them. More detail is provided on the reasons for discarding different measures. 

A new part is introduced in section 5 to explain how the remaining measures have been put 
together to provide a comprehensive set of Policy Options. 

The  Policy  Options  have  been  reviewed  and  additional  options  without  interoperability  and 
also with a higher level of energy efficiency ambition have been included 

(3)  The  robustness  of  the  analysis  of  impacts  of  specific  measures  and  options  is  not 
properly demonstrated due to unclear assumptions and inadequate acknowledgment of 
uncertainties. 

Amendments made to the IA in response 

Information  has  been  included  on  the  key  assumptions  on  the  reaction  of  consumers  to 
interoperability and the uptake by manufacturers of voluntary unbundling that is mostly taken 
from  the  preceding  Common  Charger  Impact  Assessment.  Since  there  is  uncertainty  about 
this, sensitivity tests on these factors have been carried out with the model and the results are 
reported in annex 13 as well as briefly in the main text. 

Text has been added on the likely beneficial impact on competitiveness of EU manufacturers. 
However, as made clear in the IA, since manufacturing takes place in Asia the importance of 
this  is  limited.  The  discussion  of  the  impacts  on  innovation  has  been  enhanced,  however, 
these are likely to be relatively small as ecodesign requirements use existing technology. 

The report has been restructured to follow the amended design of the Policy Options. 

The  modelling  and  assumptions  supporting  the  assessment  have  been  thoroughly  reviewed 
and  where  appropriate  updated.  A  full  final  series  of  model  runs  has  been  carried  out 
addressing the modified set of policy options. This includes the correction of minor errors that 
have been identified as well as adjustments based on information that came to light later in the 
analysis. 

It has been verified that all costs in the policy assessment are shown as overall costs not unit 
costs. For OIOO the aggregate figure is included. 

Due to  the requirements  of the Ecodesign  Directive, it is clarified in  section 1.1 that the IA 
analysis is primarily based on consumer welfare. Costs including external costs are provided 
for information and show these are relatively small and an assessment is included in section 
8.3 of whether there are higher environmental benefits from other Policy Options  that could 
justify choice of a different preferred option. 

(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. 

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Amendments made to the IA in response 

The  comparison  of  the  Policy  Options  has  been  thoroughly  revised  following  the  review  of 
the  objectives  and  the  restructuring  of  the  Policy  Options.  The  assessment  is  carried  out  in 
relation to effectiveness, efficiency, coherence and least life cycle cost. 

In terms of coherence, the process followed has ensured that incoherent measures have been 
ruled  out.  Detail  on  these  is  provided  in  annex  11  on  discarded  measures,  where  the 
descriptions explain whether they have been ruled out due to poor coherence with other EU 
policy objectives.  

In  view  of  this,  in  terms  of  assessing  coherence  of  the  Policy  Options,  the  primary 
distinguishing factor is their contribution to Circular Economy goals in relation to material in 
the EPS and this has been explicitly scored.  

No  assessment  of  proportionality  is  included  since  as  an  implementing  measure  under  the 
Ecodesign Directive there is no choice of instrument available. It is a Regulation that is being 
reviewed, and the only alternative would be to abolish it, however as shown in the Evaluation, 
its retention is justified.  

The  methodology  used  to  compare  the  Policy  Options  is  based  on  the  assessment  of  their 
impacts in relation to the objectives in terms of their effective (contribution to SO1 and SO2) 
efficiency (the impact per unit cost) and whether they result in the lowest life cycle cost and 
how coherent they are.  

The scoring system used to compare the Policy Options is clearly explained. For quantifiable 
aspects (energy, environmental impacts and costs) the actual figures from the modelling are 
used. To provide a score of 1 to 3, the results are divided into 3 equal bands between the worst 
and best performer and POs within each band are scored 1 to 3 respectively. For Life Cycle 
Cost a specific approach is used based on the location of the combinations of the efficiency 
measures in the life cycle cost curve. Zero marks are given to combinations leading to costs 
above BAU. 

The  performance  with  regard  to  lowest  life  cycle  consumer  cost  is  shown  by  the  consumer 
cost  figures.  The  addition  of  lowest  life  cycle  consumer  cost  to  the  energy  objective  will 
slightly amend the assessment of effectiveness.   

The  trade-offs  are  illustrated  in  a  radar  diagram  showing  what  each  Policy  Option  delivers 
against the measured outcomes. This is supported by a written description of the trade-offs. 

Following resubmission of the draft Impact Assessment the RSB gave a positive opinion with 
comments  on  18  April  2024.  The  table  below  shows  the  specific  RSB  comments  and  the 
action that has been taken: 

(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. 

Amendments made to the IA in response 

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The statement in section 2.3 that the intervention was  ‘not  expected to have any significant 
impact  on  competitiveness’  has  been  expanded  to  also  state  it  is  not  expected  to  have  any 
impact on EU manufacturing. 

Text  on  the  potential  for  innovation  that  refers  to  EU  component  manufacturers  has  been 
expanded  in  the  competitiveness  assessment  with  an  example  of  a  European  company 
offering an innovative approach to reducing losses at 10% load has been added. 

Text  has  been  added  in  the  competitiveness  assessment  explaining  that  no  impact  on 
innovation in end-use products is expected since alternatives are envisaged to be permitted in 
addition to the USB-C connector and protocol on EPS. 

(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. 

Amendments made to the IA in response 

The  details  of  the  scoring  system  are  explained  in  section  7.4.  Since  the  conversion  of 
estimated values for effectiveness and efficiency into scores based on thresholds could affect 
the final rankings a sensitivity test has been added in section 9 of Annex 13 showing that this 
has no material impact on the preferred option and limited impact on the other final rankings. 

(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.  

Amendments made to the IA in response 

A completely new Annex 16 has been added to the IA that provides background information from a 
variety of sources on consumer interest in prolonging the use of products that provide a basis for the 
range of assumptions covered in the EPS reuse sensitivity tests. 

(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. 

Amendments made to the IA in response 

A summary of the measures has been included in the start of section 5 of the IA. Additional 
text  has  been  included  in  the  discussion  of  the  scope  extension  in  Annex  10  section  2,  that 
explains how e-bike chargers are being addressed in other EU legislation. 

(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. 

Table  62  has  been  added  to  Annex  17  showing  the  2035  electricity  savings  under  all  POs 

Amendments made to the IA in response 

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represented as a proportion of the final energy savings required by 2030 under the EED target. 

(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 obligatory table on total One-in One-out costs has been added in Annex 3. 

Amendments made to the IA in response 

4.  Evidence, sources and quality 

The main evidence gathering for this impact assessment has been carried out under a contract 
by  BioIS  and  Fraunhofer  IZM  consultants.  This  has  been  supplemented  by  a  public 
consultation  and  meeting  of  the  Consultation  Forum.  Bilateral  meetings  with  industry  have 
provided valuable insights and helped to verify assumptions.  

The impact of the different policy options were modelled as part of the support contract based 
on assumptions about sales, stock, consumer behaviour and product prices. Assumptions for 
electricity  prices,  GHG  intensity  and  fuel  use  for  electricity  generation  were  taken  from 
PRIMES  scenarios  to  ensure  coherence  and  consistency  of  the  impact  assessment  baseline 
scenario  with  existing  energy  policies.  Pollutant  emissions  from  electricity  generation  are 
taken from EEA data. 

Because  most  EPS  are  sold  bundled  with  other  products  the  assumptions  on  total  sales  and 
value cannot be considered robust. Sensitivity tests were used to verify that these factors do 
not  have  significant  consequences  for  the  choice  of  preferred  option.  Consumer  behaviour 
with greater EPS interoperability is also uncertain. This is highly relevant to the overall results 
and sensitivity tests have been performed to illustrate the impacts. 

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ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) 

Stakeholder information has been gathered in a variety of ways.  

1.  A Call for Evidence was published and feedback was sought from 6 April till 4 May 

2022.  A first Consultation Forum meeting was held in February 2023.  

The main issues raised are outlined below: 

General issues  

Concern was raised by ECOS about limitations of the “Back-to-back evaluation” procedure. 
In  particular  the  risk  of  insufficient  opportunities  for  stakeholder  comments  to  be  provided 
and  considered.  Concern  was  also  expressed  that  technical  analysis  could  be  neglected 
without multiple opportunities for stakeholder input.  

ECOS  strongly  support  work  on  circular  economy  and  interoperability  but  wisht  to  ensure 
that the Article 7 review clause aspects are analysed during the review as intended. 

Scope extension 

Both  ECOS  and  ANEC  /  BEUC  requested  that  the  scope  of  the  regulation  should  be 
expanded. Specific aspects mentioned were: high power EPS (covered by US DOE); Active 
Power over Ethernet injectors and EPS used with products not included in Annex I.  

Interoperability 

A substantial number of views were expressed about interoperability.  

Scepticism was expressed by APPLiA on the grounds of differing safety and electromagnetic 
compatibility requirements and standards and challenges relating to certification.  

Digital Europe challenged USB-PD requirements, among other things claiming on technical 
grounds  that  these  power  supplies  are  not  suitable  for  the  products  which  are  not  battery 
powered.  

EPTA-EGMF and EPBA in principle agreed to inter-operability requirements, provided that 
they do not apply to products intended to be charged outdoors.  

While  not  opposing  interoperability,  ANEC  /  BEUC  stated  that  it  was  important  to  look  at 
minimum requirements to address these issues. They consider it important to fully assess how 
consumer  use  patterns  might  change  with  interoperability  and  the  potential  for  purchase  of 
refurbished products and used devices on the second hand market. 

FRIWO  indicated  that  requiring  from  an  EPS  to  be  IPX4  protected  and  designed  to  be 
operated in a wet environment would increase its cost by several Euro. 

In favour were the European Anti-Poverty Network Nederland. 

The IARU also  welcomed regulations for a universal  EPS and unbundling as set out  in  the 
Common Charger initiative. 

One EU citizen stated that while products may more expensive, in the end, the costs for the 
economy will be lower. While in favour of fewer rules and a voluntary approach this citizen 
stated that rules would be needed for EPS to be standardised and flexible. 

Another EU citizen stated that with the existence of USB Extended Power Range there is no 
barrier to  interoperable  EPS although with some exceptions needed. They claimed the main 
benefit  would  be  lower  CO2  footprint  and  there  should  be  no  loopholes  for  power  supplies 

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less  than  240W.  The  same  citizen  stated  that  cables  must  not  be  fixed  to  the  EPS  but  are 
consumables. 

ITI argue for a voluntary approach to common charging. They note the voluntary approach to 
common charging through memoranda of understanding (MOUs) and industry collaboration. 
They  claim  this  approach  fosters  innovation  and  convergence,  while  providing  consumers 
with  safe, increasingly interoperable options. They refer to  the 2021  IA  statement that most 
mobile phones and EPS are interoperable. ITI state the market has demonstrated commitment 
with  broad  adoption  of 
interoperable, 
energy‐efficient and smart charging handling the power needs of different devices. ITI argue 
that  regulation  in  multiple  legal  instruments  risks  fragmentation  and  inconsistencies.  They 
favour  a  voluntary  approach  based  on  internationally-agreed  standards  such  as  the  EN  IEC 
63002 standard for common charging interoperability.  

technologies  enabling  more 

latest  USB 

the 

Unbundling 

APPLiA  stated  that  safety  standards  often  require  the  EPS  to  be  sold  bundled  with  the 
product. 

ITI oppose a universal unbundling requirement arguing that it would be expensive as a result 
of requiring separate shipping of EPS and product and lead to excess packaging and transport 
CO2  emissions  and  more  ICs  in  the  EPS.  They  also  argue  that  there  are  different  technical 
requirements for different types of products including some permanently connected. 

ANEC / BEUC argue that consumers should be given an informed choice whether or not to 
buy  a  new  EPS  when  a  device  is  purchased.  They  also  argue  that  the  potential  impact  of 
obligatory unbundling on resource savings should be analysed.  

An EU citizen argued that devices must not be sold in the EU with EPS.  

Minimum energy efficiency at 10% load 

Views were split on the desirability of addressing 10% load efficiency.  

APPLiA  argue  that  there  is  no  benefit  as  operation  at  this  load  is  very  limited  and  battery 
charging shuts off before that low output.  

ITI argued that 10% load efficiency should be aligned with U.S. DoE requirements. 

In  contrast  ECOS  and  ANEC/BEUC  stated  that  it  was  important  to  look  at  the  10%  load 
level.  Further  energy  savings  are  possible  and  interoperability  will  mean  that  EPS  are 
increasingly likely to be used at lower loads. It was also noted that in the previous review it 
was claimed there was insufficient evidence for setting 10% load efficiency requirements. The 
10% load efficiency information requirement was included to provide that data. 

Energy efficiency at other load points 

ECOS consider it important to consider a metric setting minimum efficiency requirements at 
each loading points (10%, 25%, 50%, 75% and 100%) without averaging them. 

APPLiA and Digital Europe require alignment with the measurement method of the US DoE 
which considers only the highest and the lowest voltage. 

Energy efficiency requirements for wireless charging 

There  was  general  support  for  the  intention  to  introduce  active  energy  efficiency  limits  for 
wireless charging and the energy savings potential of this. 

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APPLiA  stated  it  was  necessary  to  differentiate  active  energy  efficiency  requirements  with 
transmitted power. Absolute savings potentials are much higher for high-power applications. 
APPLiA  also  stated  that  the  coupling  factor  is  a  relevant  parameter  for  wireless  charging. 
Active  efficiency  doesn’t  only  depend  on  circuitry.  These  factors  are  influenced  by  device 
size  and  geometry  and  can’t  solely  be  optimised  for  energy  efficiency.  It  proposed  to 
differentiate efficiency requirements by the coupling factor, and set harmonised requirements 
for  determining  it.  APPLiA  also  state  that  product-group  specific  safety  requirements  may 
impact  active  energy  efficiency.  Appliances  that  need  to  withstand  environmental  stresses 
require safety measures and these need to be taken in account. 

ITI are concerned that regulation of wireless charging on the EPS side must be coordinated 
with regulation on the device side to avoid conflicting and counter-productive regulations. If 
pursued wireless charging regulation should be based on voluntary harmonised standards.  

ANEC/BEUC and ECOS stated that wireless charging is becoming increasingly popular. The 
possibility  of  introducing  energy  efficiency  and  information  requirements  for  wireless 
chargers needs to be assessed in light of the wide range of performance. US DoE is currently 
developing a rulemaking to address wireless charging. 

Consumer information 

ECOS believe that minimum information requirements for cables and EPS need to be set to 
provide consumers with the information they need and avoid confusion. 

USB-PD limits 

A number of responses refer to limits of USB-PD. The Hager Group noted that there are many 
uses requiring voltage or voltage/current combinations not provided by it. Also EPS located in 
electrical installations powering will not be able to comply with USB EPS since they transmit 
data on the same wires as the power.  

ANEC/BEUC stated it was important to ensure consistency between the new ecodesign rules 
and  the  Radio  Equipment  Directive  to  ensure  interoperability  of  fast  charging  technology 
across EPS.  

ANEC/BEUC  agree  on  the  need  to  introduce  information  requirements  and  require 
compliance with USB-PD specifications for all or a subset of EPS under the revised scope.  

An EU Citizen also stated their support for common EPS for low-power devices but not for 
higher power devices.  

International aspects 

ITI argue in favour of developing harmonised EU standards based on international standards 
such as IEC 63002 and IEC 62680-x USB standards. Any additional requirements not covered 
by these should be focused on the EPS rather than the device.  ITI argue that manufacturers 
must be able to use the latest versions of international standards in products provided to the 
EU market to allow for innovation and improvement. They also argue for allowing the use of 
legacy USB-A connectors and USB Type-C(r) connectors during the transition.  

ITI state that any pictogram or other information requirements for EPSs should be developed 
in  coordination  with  equivalent  device-side  requirements.  Such  requirements  should  be 
developed in close cooperation with industry experts.  

Voluntary  adoption  of  the  IEC/EN  USB  common  charging  interoperability  standards  is 
argued to be the best approach by  ITI to best support market implementation across a wide 
product range while enabling innovation. There is no need for a unique EU EPS certification 

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requirement. Any EU logo or certification requirements must be aligned with USB-IF charger 
certification and logo program. 

ITI  state  that  consideration  is  needed  for  information  requirements  to  support  consumer 
understanding for EPSs implementing proprietary charging protocols in addition to USB-PD.  

Starkey  Laboratories  state  that  EPS  efficiency  and  environmental  regulations  should  be 
harmonised  globally.  This  condition  is  achieved  by  current  Level  VI  requirements.  Higher 
efficiency should be harmonised with North American, Asian, and Australian requirements.  

Spectrum pollution 

The  IARU  noted  the  potential  of  switching  EPS,  to  contribute  to  spectrum  pollution  as 
assessed  in  the  evaluation  of  the  EMC  Directive.    A  report  by  EMC  ADCOs  showed  only 
56% of devices tested met the technical emissions compliance tests. They noted that lacking 
standards  for  cables  can  result  in  poor  quality  and  testing  requirements  should  therefore  
reflect typical EPS use cases with associated cabling. An EU citizen also raised the problem 
of harmonic interference.  

Spare parts 

Nintendo stated that the provision of spare parts should be excluded from the requirements.  

Timing 

The Hager Group noted that EPS requirements have recently been adapted to the requirements 
of  the  previous  regulation  adopted  in  2019.  Industry  needs  stability  and  they  oppose  any 
change.  

Applia  and  Nintendo  requested  that  an  adequate  period  be  allowed  between  publication  of 
the  regulation  and  the  deadline  for  application  of  the  requirements  to  allow  manufacturers 
time to implement changes.  

2.  Additional bilateral contacts have taken place with industry and regulatory bodies. 

A second Consultation Forum meeting was held in November 2023. 

The main issues raised are outlined below: 

APPLiA  stresses  the  need  for  sufficient  transition  periods  (2  years  for  energy  efficiency,  5 
years for interoperability) in the EPS regulation. They oppose splitting battery chargers, citing 
efficiency concerns. APPLiA suggests clarifications to definitions and recommends different 
transition  periods  for  compliance.  They  oppose  a  minimum  efficiency  requirement  at  10% 
load and provide recommendations for clarifications and amendments to various points in the 
annexes,  emphasizing  the  importance  of  clarity  and  addressing  potential  challenges  with 
proposed requirements. 

Austria  advocates  for  prompt  finalization  of  ecodesign  regulations  for  external  power 
supplies  by  Q1/24,  prioritizing  resources  for  higher-energy-saving  product  groups.  They 
support exemptions for EPS for electric bikes and those with water ingress protection above 
IP0. Additionally, they endorse introducing energy efficiency requirements for the 10% load 
level  and  wireless  chargers,  emphasizing  the  need  for  clear  packaging  and  nameplate 
information  to  aid  product  selection  and  proposing  a  durability  requirement  of  at  least  10 
years  of  continual  operation  at  maximum  power,  aiming  to  balance  energy  efficiency 
improvements with simplicity and consumer guidance. 

CECAPI,  the  European  Committee  of  Electrical  Installation  Equipment  Manufacturers, 
suggests clarifications on scope, extension of transition periods, adjustments for active Power 

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Over Ethernet injectors and fixed home/building power distribution systems, and refinement 
of definitions for low voltage and multiple voltage external power supplies. They also propose 
changes  regarding  containing  products,  markings,  durability  requirements,  and  precision  of 
power  and  voltage.  CECAPI  urges  alignment  with  existing  regulations,  practicality,  and 
market competitiveness. 

DIGITALEUROPE  emphasises  the  importance  of  these  supplies  in  various  IT  equipment, 
they express concerns about the proposed requirements, which could necessitate redesigning 
most existing products, leading to disruptions in availability and an increase in non-compliant 
products and waste. They stress the need for proper testing methods and standards to ensure 
enforceability,  safety,  energy  efficiency,  and  minimal  costs.  Technical  recommendations 
include  durability/reliability,  energy  efficiency  at  10%  load,  and  marking  requirements, 
although some are still under assessment due to the diverse applications and sectors involved. 
In  the  same  context  Apple  explained  potential  issues  related  to  the  peak  power  demand  of 
certain  end-devices  and  outlined  potential  challenges  for  end  devices  due  to  the  limited 
voltage/current combinations of the USB-PD standard. 

Denmark  highlights  several  issues  that  the  Commission  should  consider,  including  lacking 
requirements on active efficiency of wireless charging, tighter active efficiency requirements 
due  to  new  semiconductor  technology,  and  information  requirements  related  to  wireless 
chargers  and  charging  pads.  They  also  emphasise  the  need  for  durability  requirements, 
repairability,  and  clear  marking  of  plastic  parts  to  facilitate  plastic  sorting.  Additionally, 
Denmark supports requirements on design for disassembly to allow for the separation of key 
components such as capacitors for proper waste treatment. 

ECOS, EEB, Deutsche Umwelthilfe, and Coolproducts applaud the widened product scope 
and  improved  efficiency  requirements  proposed  for  external  power  supplies.  It  supports 
measures like EPS durability standards and limitations on non-compliant EPS sales. However, 
it  raises  concerns  regarding  scope  exemptions  for  industrial  supplies,  unclear  definitions  of 
wireless  chargers,  and  enforcement  issues.  The  paper  recommends  clarifying  definitions, 
aligning enforcement transition times, and strengthening efficiency standards while urging for 
clearer  regulations  to  address  ambiguity.  Additionally,  it  calls  for  supplementary  studies  to 
bolster market surveillance and quantify energy consumption variations in wireless charging 
compared to wired alternatives. 

EPSMA  highlights  uncertainties  regarding  the  10-year  lifespan  requirement,  emphasizing 
differences in application areas and challenges in defining "end of life." They stress intrinsic 
and  extrinsic  factors  influencing  EPS  lifespan  and  note  the  lack  of  standardized  calculation 
methods.  EPSMA  opposes  mandating  a  minimum  EPS  lifespan,  advocating  for  market 
regulation  and  highlighting  challenges  in  verifying  MTBF  (Mean  Time  Between  Failures) 
figures. They underscore that MTBF alone does  not  reflect  durability or quality,  offering to 
discuss their position further and inviting Commission representatives to a meeting. 

EPTA and EGMF argue against extending the regulation to include power tools and garden 
machinery  due  to  environmental  and  economic  concerns.  They  oppose  mandating  separate 
USB power supplies for battery chargers, citing efficiency, material,  and EMC issues. They 
also  highlight  inconsistencies  in  exemptions  and  interoperability  requirements,  proposing 
revisions  for  clarity.  Overall,  they  call  for  a  balanced  approach  that  considers  industry-
specific challenges and consumer needs. 

FRIWO  highlights  challenges  in  transitioning  to  USB  power  supplies,  especially  for 
applications  requiring  >5A  currents,  noting  efficiency  loss  and  increased  costs.  They 

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recommend extending spare parts availability to prevent premature scrapping of applications, 
and  aligning  transition  periods  with  international  standards.  They  raise  concerns  about 
efficiency  requirements'  stringency  and  advocate  for  a  48-month  transition  period  for 
application redesigns to  minimize resource waste. Additionally, they propose exclusions  for 
certain  products  like  DIN-rail  power  supplies  and  one-stage  battery  chargers  from  USB 
requirements, citing practicality and environmental concerns. FRIWO also raises issues with 
durability  requirements,  suggesting  considerations  for  ambient  temperature,  verification 
methods,  costs,  load  points,  and  MTBF  calculations.  They  recommend  removing  surge 
requirements and support flexible testing methods based on manufacturer specifications. 

Germany emphasises the importance of adequate transition periods and exemptions tailored 
to  commercial  and  industrial  power  supplies.  They  stress  the  need  for  clarity  in  definitions 
such  as  "nameplate  output  power"  and  "peak  power  demand,"  proposing  clearer  criteria  to 
avoid  ambiguity.  Moreover,  Germany  recommends  reevaluating  durability  requirements, 
suggesting  a  more  realistic  approach  that  balances  longevity  with  cost-effectiveness.  They 
highlight  the  necessity  for  precise  information  requirements,  instruction  manuals,  and 
technical  documentation  to  ensure  compliance  and  clarity  for  manufacturers  and  consumers 
alike.  Additionally,  they  advocate  for  standardization  in  cable  length  and  cross-sections, 
aligning with international standards for consistency and interoperability. 

Gigaset  expresses  deep  concern  over  safety  and  technical  issues  in  the  current  draft  of  the 
working  document  supporting  the  revision  of  Commission  Regulation  (EU)  2019/1782. 
Highlighting  critical  problems  with  USB-EPS,  including  safety  conflicts  with  EN  62368-1 
standards, failure to meet resistibility requirements, audio distortion from ground loops, and 
unsuitability  for  devices  requiring  continuous  24/7  power  supply,  Gigaset  proposes 
modifications  to  eliminate  landline-connected  devices  from  the  scope,  extend  the  transition 
period for charging cradles EPS to a minimum of four years, and make an exception for EPS 
as  spare  parts  for  devices  under  2023/1670  regulations,  aiming  to  mitigate  adverse 
environmental and economic impacts. 

JBCE  and  JP4EE  raise  concerns  about  durability  and  resistibility  requirements,  proposing 
nuanced criteria instead of uniform standards. They suggest modifications to the definition of 
'audio equipment' and advocated for a longer grace period for service parts. Additionally, they 
raise  issues  with  the  scope  expansion,  call  for  a  sufficient  transition  period  for 
implementation, and recommend against displaying efficiency on nameplates. 

Märklin suggests exempting electric trains  from  mandatory USB-PD supplies due to  safety 
concerns.  Electric  trains,  including  both  toy  and  model  versions,  historically  use  safety 
transformers without a protective earth connection for galvanic insulation. In contrast, USB-
PD  supplies  often  have  a  protective  earth  connection,  which  could  pose  safety  risks, 
especially when powering insulated track sections. Therefore, exempting electric trains from 
USB-PD requirements is advisable to ensure safety in their operation. 

The Netherlands  emphasise stricter specifications for exemptions,  aligning  entry into force 
of  requirements,  seeking  alignment  with  US  DOE  standards,  advocating  for  efficient 
verification of durability requirements, proposing separation and alignment of circumvention 
and  software  update  articles,  and  suggesting  adjustments  to  information  requirements 
regarding USB power delivery markings. 

STIHL raises concerns regarding the proposed requirement for battery chargers with a rated 
input  power  <  240  W  to  be  supplied  by  USB  sources.  They  argue  that  this  would  reduce 
charging  system  efficiency,  contravening  energy  efficiency  goals  and  increasing  lifecycle 

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costs.  They  provide  a  case  study  comparing  the  efficiency  of  USB-powered  and  mains-
powered  battery  chargers,  showing  a  significant  efficiency  loss  with  USB  charging  due  to 
voltage conversion and cable losses. 

STMicroelectronics remind that PPS is an optional feature of USB-PD, initially intended for 
battery charging, that comes with significant additional complexity and cost, while AVS starts 
at  9V/27W to  allow low cost  EPS below that threshold. They also  challenge the exceptions 
proposed for high voltage / low current demand, and the durability requirements. 

Sweden  welcomes  the  scope  enlargement  to  include  various  products  and  supporting 
increased  energy  efficiency  requirements.  However,  concerns  are  raised  about  overly 
stringent  requirements  for  multiple  voltage  output  and  questions  are  posed  regarding  the 
exception for chargers of batteries in light mobility means and the differing energy efficiency 
requirements based on maximum current level. Additionally, Sweden suggests extending the 
timeframe for implementation to accommodate product redesign  and production. It supports 
interoperability  and  information  requirements  but  seeks  clarification  on  the  verifiability  of 
durability requirements. 

USB-IF explains in detail the USB-PD power curve and other relevant details from the USB 
standards,  including  the  specific  features  PPS  and  AVS.  In  particular  they  stress  the 
backwards compatibility  of the standards and expressed concerns about  referring to  specific 
revisions in the regulatory text. The position is supported also by Granite River Labs.   

ZVEI  followed  among  others  by  Arburg,  Beckhoff,  Emerson,  EPSMA,  Inpotron, 
Phoenix,  Puls,  Siemens  and  TDK  advocate  for  maintaining  the  exemption  of  commercial 
and  industrial  power  supplies  from  EU  Regulation  2019/1782.  They  argue  that  these  power 
supplies are optimized for specific operating points and unlikely to achieve energy savings if 
considered independently. ZVEI emphasizes that factors like additional functions and energy-
saving  measures  make  the  "no-load"  state  irrelevant  for  these  power  supplies.  They  warn 
against  approving  the  proposal  as  is,  stating  it  would  disadvantage  European  producers  and 
customers without providing additional benefits. 

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ANNEX 3: WHO IS AFFECTED AND HOW? 

Practical implications of the initiative 

The  initiative  will  concern  all  of  EU  population35,  manufacturers  of  electronic  devices  for 
consumer and office use as far as these are powered or potentially powered by external power 
supplies in a power range up to 250W, and manufacturers of external power supplies. Further, 
there will be a relevant impact on retailers. 

Consumers: the initiative will directly affect all users of electronic devices with EPS in scope 
of  virtually  all  EU  citizens  who,  without  this  initiative,  would  continue  using  electronic 
devices with  a proprietary or legacy types of connectors.  In the short term,  they may suffer 
inconvenience, if manufacturers increasingly offer unbundled devices, i.e. selling end-devices 
without  EPS,  as  intended  by  this  initiative.  This  would  result  in  a  transitional  phase  that 
consumers need to pay attention, whether a device is sold with or without an EPS and if an 
already owned EPS is compatible with the power requirement of the purchased device. Over 
time consumers will be equipped with a sufficient number of interoperable EPS to get used to 
the option to purchase a device without EPS. Consumers will also benefit from the fact, that 
EPS  costs  even  with  implementing  USB  compatibility  at  least  remain  stable,  given  that  the 
significantly  higher  mark-ups  seen  in  the  market  frequently  for  proprietary  EPS  would  be 
obsolete,  if  an  interoperable  EPS  could  be  sourced  from  various  vendors.  Further,  as 
consumers  occasionally  face  the  situation,  that  an  EPS  is  defect,  but  a  replacement  is  not 
available,  which  then  terminates  also  the  use  of  the  powered  device,  or  that  a  device 
potentially could be reused, but the EPS got lost, this initiative would result also in some end 
devices being used for an extended period of time, saving consumers acquisition costs for new 
end-devices. 

Manufacturers of electronic devices: Manufacturers of those devices covered already by the 
interoperability  requirement  of  the  amended  Radio  Equipment  Directive  will  not  face 
additional  business  impacts.  Manufacturers  of  devices  in  scope  of  the  interoperability 
requirements of this initiative would entail adaptation costs for the end devices to implement a 
USB Type-C receptacle and a circuitry for the negotiation process between EPS and powered 
device, and potentially to adapt internally the voltage level of the electronics circuitry to those 
supported  by  the  USB-PD  specification.  The  main  impact  is  associated  with  necessity  for 
such  redesigns.  Current  product  design  and  product  development  expenses  could  become 
stranded investments, if requirements stemming from the initiative are not considered by the 
manufacturers in due time. Mid- to long-term the manufacturers and suppliers would benefit 
from the cost reductions of unbundling, if the manufacturer decides to do this on a voluntary 
basis.  This  would  reduce  product  costs  significantly.  Manufacturers  would  face  additional 
logistics costs for shipping unbundled EPS (if they still continue to offer EPSs once these are 
interoperable), but it is expected that this would be more than compensated by the significant 
logistics  advantage  of  product  packages  without  EPS  being  significantly  smaller  in  case  of 
small devices (such as cordless phones, home network equipment, handheld devices, battery 
chargers etc.). This volume and weight savings effect is less relevant for larger end devices. 
Unbundling however is also related to business risks, given the uncertainty if consumers and 
other purchasers appreciate the option to purchase an unbundled device or if they just expect 

35 stock of approximately 1.8bn EPS in use in the EU, and approximately 520mln new EPS sold annually in the 
EU, which is more than one EPS sold per EU citizen (EU’s population being 446.7mln as of 1 January 2022). 

EN 

63 

  EN 

 
 
 
 
to get an EPS delivered with a product. Further risks arise from users potentially using non-
compliant or low quality EPS with an end device, resulting potentially in liability and brand 
reputation  issues.  Manufacturers  of  external  power  supplies  will  need  to  readjust  their 
product portfolio towards USB power supplies, which might result in further consolidation in 
the market. Actually, with less variety of EPS specifications, EPS design and production costs 
would  as  a  tendency  go  down,  given  scaling  effects.  As  the  total  number  of  sold  EPS  is 
expected to drop significantly, overall turnover of EPS manufacturers would be reduced. 

SMEs: As there is a small share of European manufacturing SMEs in the market segment of 
consumer  applications  and  office  equipment,  the  effect  on  SMEs  in  particular  will  be  very 
limited. Those SMEs being affected and supplying a comparingly smaller number of products 
to  the  market  actually  would  benefit  from  this  initiative  and  as  a  consequence  a  more 
widespread existence of USB and USB-PD EPSs in households, as they do not have to bear 
the costs of specifying and acquiring an EPS. This tendency is already seen for small gadgets, 
which  are  occasionally  distributed  without  EPS  already  but  with  an  USB  receptacle.  These 
product concepts definitely would benefit from this initiative. The standardisation of charging 
solutions  would  create  a  level  playing  field  for  companies.  Refurbishers,  which  in  their 
majority are SMEs, would benefit from this initiative, as lost EPS are frequently a problem for 
reselling  used  equipment.  With  this  initiative  in  place,  refurbishers  easily  could  source 
replacement EPS or rely on the broad availability of interoperable EPSs. This initiative would 
stimulate the reuse and refurbishment market. 

Retailers:  Stationary  and  online  retail  would  be  challenged  by  the  fact,  that  some  products 
would  be  sold  with,  others  without  an  EPS  and  consumers  (see  above)  need  to  be  clearly 
informed, what the package includes. Retailers, just as manufacturers, would face additional 
logistics costs for shipping unbundled EPS, but separate sales of stand-alone EPS would also 
yield  additional  revenue  for  retailers,  although  without  the  current  significant  mark-ups  for 
proprietary EPS and cables. It is expected that there would be significant logistics advantage 
also  for  retailers  as  product  packages  without  EPS  can  be  significantly  smaller  in  case  of 
small devices. This volume and weight savings effect is less relevant for larger end devices. 
Overall, the impact on retailers and distributors is expected to be positive. 

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.  

I. Overview of Benefits (total for all provisions) – Preferred Option PO6 

Description 

Amount 

Comments 

Direct benefits 

Environmental benefits  GHG emissions reductions: 70kt CO2eq 

yearly36 

Incentivising the 
unbundling of EPS 
brings the biggest 

36 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 

EN 

64 

  EN 

 
 
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. 

Indirect benefits 

Extended lifetime of 
end-devices 

Not quantifiable 

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 
(refurbishment of 
devices with lost EPS): 
No data 

Broad availability of 
compatible 
replacements EPS in 
case of EPS defects 

Table 16 - Summary of costs and benefits 

EN 

65 

  EN 

 
 
II. Overview of costs – Preferred option PO6 

Citizens/Consumers  

Businesses 

Administrations 

One-off 

Recurrent 

One-off 

Recurrent 

One-off 

Recurrent 

N/A  

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 
compatibility of 
the end-device 
(for products re-
designed for USB 
compatibility due 
to this regulation) 

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

EPS redesigned, 
USB cable, surge 
protection. 

For manufacturers 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) 

Loss of turnover by 
worldwide 
industries and retail 
channels in EU of € 
600mln yearly 
compared to the 
baseline. 

Capacity for 
additional test 
requirements: 
negligible 
costs. 

Not quantifiable 

New test 
requirements to 
verify claimed 
USB 
compatibility, 
but less product 
models in the 
market to be 
expected. 

Loss of revenue due 
to no further sales 
of over-priced 
proprietary 
replacement EPS. 

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

Direct 
costs for 
EPS 

Direct 
cost for 
end-
devices 

(a) Measure on 
interoperability – 
M2b   

Indirect 
costs 

N/A 

N/A 

N/A 

Losses in turnover 
due to slightly less 
end-device sales 

N/A 

N/A 

66 

 
 
 
(those, which 
would otherwise 
been replaced due 
to a defect EPS): 
Not quantifiable 

Increased EPS costs 
per unit: €0.04-0.18 

N/A 

Additional tests 
costs for low-
load: negligible 

N/A 

N/A 

N/A 

Capacity for 
additional test 
requirements: 
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 
requirements to 
verify claimed 
lifetime (time 
consuming test 
procedure), test 
costs roughly in 
the range of 
€100 per unit to 
be expected 

(b) Measure on 
reducing energy 
consumption – M4a  

Direct 
costs 

Increased EPS 
costs €0.04 - 0.18 
per unit in 
average 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

Indirect 
costs 

N/A 

(c) Action on 
durability of EPS – 
M6 

Direct 
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 

67 

 
 
measure on 
interoperability 
(M2b) 

Indirect 
costs 

N/A 

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

Direct 
costs 

Indirect 
costs 

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. 

No significant 
changes to actual 
charger costs 
expected 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

New market 
surveillance 
actions on 
battery chargers 

Additional costs on 
redesigning 
chargers for USB-
compatibility, but 
also savings on bill-
of-materials costs 
for chargers with 
(as of now) 
integrated AC-DC 
circuitry, might 
materialise as 
additional revenue. 

N/A 

N/A 

N/A 

N/A 

N/A 

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

Direct 
costs 

Increased 
wireless charger 
costs €0.15 per 
unit (average) 

N/A 

N/A 

Increased wireless 
charger costs per 
unit: €0.15 

N/A 

New market 
surveillance 
actions on 
wireless 
chargers 

68 

 
 
Indirect 
costs 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

III. Application of the ‘one in, one out’ approach – Preferred option PO6 

Table 17 - Overview of costs – Preferred option PO6 

[M€] 

One-off 
(annualised total net present value over the relevant period) 

Recurrent 
(nominal values per year) 

Businesses 

New administrative burdens (INs) 

Removed administrative burdens (OUTs) 

Net administrative burdens 

Adjustment costs 

Citizens 

New administrative burdens (INs) 

Removed administrative burdens (OUTs) 

Net administrative burdens 

Adjustment costs 

Total administrative burdens 

- 

- 

- 

as above 

- 

- 

- 

as above 

- 

400 k€ 

- 

400 k€ 

as above 

- 

- 

- 

as above 

400 k€ 

Total 

400 k€ 

- 

400 k€ 

- 

- 

- 

400 k€ 

Table 18 - Administrative burden - costs - 'One in, one out'

69 

 
 
 
 
ANNEX 4: ANALYTICAL METHODS  

1.  Methodology Approach 

The  impact  assessment  is  based  on  an  analytical  model  aligned  with  the  Methodology  for 
Ecodesign  of Energy-related Products  (MEErP).  For the purposes of analysing the impacts, 
the product  category is sub-divided into several  Base Cases to  represent  the various market 
segments and end-applications powered by external power supplies. These are chosen as such 
because they represent sufficiently different characteristics or use-profiles. 

Policy measures are assessed first on the product level to establish a Life Cycle Cost curve to 
determine the point of Least Life Cycle Costs. These are then used to guide the construction 
of policy options. 

2.  Model description 

To  be  consistent  with  prior  long-term  projections,  e.g.  prior  revisions  of  the  ecodesign 
regulation for external power supplies and the Ecodesign Impact Assessment, the definition 
of these Base Cases incorporates these earlier definitions. Additional Base Cases have been 
introduced to allow for a granular modelling of policy options such as extending the scope, 
mandatory  interoperability  for  all  EPS  in  scope  or  only  a  sub-set,  and  mandatory 
externalisation  of  power  supply  circuitries.  The  Base  Cases  assessed  in  this  impact 
assessment are listed in Table 19. 

Base Cases: output power ranges and typical end-applications 
EPS ≤ 6W, low-V (e.g. mobile phone) 
EPS ≤ 6W (personal care) 
EPS 6-10W (e.g. tablets, smart phones etc.) 
EPS 10-12W (e.g. small network equipment, set-top boxes)  
EPS 15-20W (e.g. portable devices, portable game consoles) 
EPS 15W (personal care) 
EPS 20-30W (e.g. notebook computer) 
EPS 30-65W, multiple-V (e.g. multi-device univ. chargers) 
EPS 30-65W (e.g. high-end notebook computers) 
EPS 65-120W (e.g. high-end notebook computers) 
EPS 65-120W, multiple-V (e.g. stationary game consoles) 
EPS 12-15W (e.g. loudspeakers, sound systems) 

a. 
aa. 
b. 
c. 
d. 
dd. 
e. 
f. 
g. 
h. 
i. 
j. 
kk.  Wireless chargers 
ll. 
mm. 

EPS 9 W (for standard-cell battery chargers) 
Internal power circuitry (in standard-cell table-top battery chargers) 

Table 19: Base Case definitions 

Each  of  the  Base  Cases  is  modelled  in  terms  of  bill-of-materials,  distribution  scenario,  use 
phase  impacts,  end-of-life  scenario,  economic  figures  and  stock  and  sales  in  an  Ecoreport 
spreadsheet,  which  has  been  developed  as  a  tool  to  apply  MEErP  consistently.  In  these 
Ecoreport spreadsheet individually the Business-as-Usual (BAU) and the other policy options 
are modelled per Base Case and for the years 2020, 2025, 2030, 2035, and 2040. A forecast 
beyond  2040  regarding  the  development  of  power  supply  technology  and  even  more  the 

70 

 
 
 
 
power demands of the various end-applications is hardly possible and therefore not covered 
by this assessment. 

The  analytical  model  is  divided  into  three  different  connected  sub-models,  each  covering  a 
different aspect of the analysis. The models are: 

A Data input module containing raw data for sales, power consumption, energy efficiencies 
and other input data gathered from the sources available for the project. The data input model 
also includes the data to model the various policy options by providing parameterised entries 
for 

Impacts of changes in electricity grid mixes in the EU 

-  Electricity costs 
- 
-  EPS lifetime 
-  EPS sales (as a calculated value following lifetime changes) 
-  Energy efficiency / energy losses in the various modes (loads) 
-  Time spent under the various loads depending on the end-application 
-  Product cost changes due to individual measures. 

A Base Case module, calculating the effects of policy options for a given year per individual 
Base Case.  

Finally, a scenario model aggregates all relevant impacts from the Base Case models for the 
study including, but not limited to:  

- 
total consumer expenditure (purchase price and electricity costs); 
- 
societal life cycle costs (consumer LCC and externalised damages); 
- 
total energy consumption in the production, use phase, and end-of-life of the products; 
-  GHG  emissions  for  the  use  phase,  production  and  end-of-life,  and  all  other 

environmental impact categories provided by MEErP; 

-  Generation of electronics waste. 

3.  Data sources, scaling and projections 

Emission factors 

Environmental  indicators  to  assess  impacts  of  the  various  options  are  those  used  in  the 
MEErP  EcoReport  tool  with  some  major  adaptations:  GHG  intensity  of  electricity  in  the 
European Union is constantly declining and electricity consumption in future years has to be 
modelled with significantly reduced kg CO2eq/kWh values. Forecast data are provided by the 
European Commission as shown in Table 20.  

Intensity 

intensity 

GHG 
indicators 
GHG 
electricity 
consumption 
CO2eq/kWh) 

2020 

2025 

2030 

2035 

2040  2045  2050 

0.227 

0.192 

0.090 

0.029 

0 

0 

0 

(kg 

Table 20 - Carbon intensity indicators of the EU electricity grid mix (source: European Commission 2023) 

71 

 
 
 
 
SO2  and  particulate  matter  (PM)  emissions  are  approximated  with  emission  factors  for 
electricity generation derived from EEA data. All other environmental indicators as regards 
the impact of electricity consumption is proportionally aligned with the GHG emissions, as a 
proxy for the level of fossil fuelled generation in the mix as shown in Table 21. 

Product 

Energy 

Water  Waste 

Emissions to Air 

to Water 

G
E
R

e
l
e
c
t
r

f
e
e
d
s
t

h
a
z
.

n
o
n
-
h
a
z
.

w
a
t
e
r
p
r
o
c
e
s

w
a
t
e
r

(
c
o
o
l
)

M
J

M
J

M
J

l
t
r
.

l
t
r
.

g

g

G
W
P

k
g
C
O
2
e
q

A
D

V
O
C

P
O
P

H
M

P
A
H

P
M

M

e
t
a
l

E
U
P

g
S
O
2
e
q

m
g

n
g

i
-

T
e
q

m
g
N

i

e
q

m
g
N

i

e
q

  m
g
g
H
g
/
2
0
e
q

m
g
P
O
4

e
q

MEErP 
as-is 

2020  

2025  

2030  

2035  

2040  

Electricity 
per MWh  9000   9000   0   0   400   142   4638   384.2  1700   201  21   91   21   36   38.74  1700  
Electricity 
per MWh  9000   9000   0   0   296.7  105.3  3441   226.7  95.8  149 16  68  16  3.7  29 
Electricity 
per MWh  9000   9000   0   0   249.7  88.63  2895   191.9  78.7  125 13  57  13  3.0  24 
Electricity 
per MWh  9000   9000   0   0   196.7  69.84  2281   89.6  51.6  99  10  45  10  2.0  19 
Electricity 
per MWh  9000   9000   0   0   149.6  53.12  1735   29.3  31.3  75  8 
Electricity 
per MWh  9000   9000   0   0   103.1  36.58  1195   0 

25.0  52  5 

1.2  14 

1.0  10 

34  8 

23  5 

1261 

1061 

836 

636 

438 

Table 21- Emission factors on electricity consumption applied in the analysis (sources: MEErP, European 
Commission 2023, EEA) 

Electricity costs 

Electricity costs vary over time. The best available forecast on future price developments is 
based on the PRIMES model shown in Table 22. Although some of the EPS in scope are used 
in  offices  and  might  also  be  used  in  other  business  environments  the  residential  electricity 
costs apply to the vast majority of EPS uses in scope. 

Electricity Rates used (€/kWh) 

2020  2025  2030  2035  2040 

RePower EU Scenarios - Opt3A 
Households 

0.176  0.192  0.250  0.242  0.224 

Table 22 - Electricity costs 2020 - 2040 (Source: European Commission, 2023) 

Stock data 

Stock  data  is  derived  from  prior  analyses  of  the  market,  considering  household  penetration 
rates for most relevant applications, estimated data from industry associations for parts of the 
EPS  market,  most  recent  data  from  other  impact  assessments,  i.e.  the  Common  Charger 
Initiative and for Ecodesign and Energy Label Regulations for mobile phones and tablets, and 
considers forecasts in terms of end device power demands and trends towards fast charging 
for  an  increasing  number  of  applications.  This  shift  is  implemented  in  the  stock  data  by 
forecasting 700 million units (i.e. almost all EPS for smartphones, tablets and similar battery 
powered  devices)  being  covered  by  Base  Case  d.  EPS  15-20W  in  2040  which  without  this 
shift  towards fast  charging would be allocated to Base Case b. EPS 6-10W.   Effects  of the 
amended Radio Equipment Directive (OJ L 315/30, 7.12.2022) are taken into account for the 
BAU scenario. 

72 

 
 
  
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Base Case 

a. EPS ≤ 6W, low-V (e.g. mobile 
phone) 
aa. EPS ≤ 6W (personal care) 

b. EPS 6-10W (e.g. tablets, smart 
phones etc.) 
c. EPS 10-12W (e.g. small 
network equipment, set-top 
boxes)  
d. EPS 15-20W (e.g. portable 
devices, portable game consoles) 
dd. EPS 15W (personal care) 

e. EPS 20-30W (e.g. notebook 
computer) 
f. EPS 30-65 W multiple-V (e.g. 
multi-device univ. chargers) 
g. EPS 30-65W (e.g. high-end 
notebook computers) 
h. EPS 65-120W (e.g. high-end 
notebook computers) 
i. EPS 65-120W multiple-V (e.g. 
stationary game consoles) 
j. EPS 12-15W (e.g. 
loudspeakers, sound systems) 
kk. Wireless chargers 

ll. EPS 9 W (for standard-cell 
battery chargers) 
Totals 

mm. Internal power circuitry (in 
standard-cell table-top battery 
chargers) 

Stock (mln. units), year 

2020 

117.99 

60.00 

2025 

87.41 

80.00 

2030 

54.28 

88.00 

2035 

23.07 

96.00 

616.69 

472.56 

208.63 

186.86 

2040 

10.24 

104.00 

158.00 

589.03 

597.15 

601.50 

605.24 

609.00 

144.70 

327.87 

630.80 

683.08 

734.77 

20.00 

67.90 

4.23 

2.46 

40.00 

64.02 

48.00 

60.98 

56.00 

56.51 

64.00 

51.86 

9.12 

12.74 

17.48 

22.15 

10.42 

19.28 

24.56 

24.59 

21.90 

14.16 

5.48 

0.02 

0.00 

17.12 

12.02 

12.11 

12.14 

12.14 

126.75 

97.80 

2.40 

132.17 

157.50 

133.17 

253.66 

133.55 

408.51 

133.55 

408.51 

2.40 

2.40 

2.40 

2.40 

1888.96 

2006.80 

2131.04 

2305.42 

2335.21 

2.40 

2.40 

2.40 

2.40 

2.40 

Table 23: Stock model BAU, EPS and related products, 2020-2040 

Lifetime 

Data on EPS use lifetime in  a BAU scenario is  derived from  other impact  assessments. i.e. 
the Common Charger Initiative and for Ecodesign and Energy Label Regulations for mobile 
phones  and  tablets.  Estimates  on  product  lifetimes  for  powered  products  are  aligned  with 
similar analysis by the US DoE for the US market. End device lifetimes are taken as a proxy 
under  the  assumption  that  currently  the  end  of  the  use  lifetime  of  the  powered  product 
typically  also  terminates  the  use  of  the  EPS.  Effects  of  the  amended  Radio  Equipment 
Directive  (OJ  L  315/30.  7.12.2022)  and  the  unbundling  requirement  are  taken  into  account 
for the BAU scenario. The BAU forecast consequently is already based on an extended EPS 
lifetime for those products covered by the RED unbundling requirements. For some product 
segments  the  shift  towards  interoperable  EPS  will  not  be  fully  completed  by  2030  (e.g. 
laptops), and the full lifetime extending potential will be reached only after 2030. 

Base Case 

2020 

2025 

a. EPS ≤ 6W low-V (e.g. mobile phone) 

aa. EPS ≤ 6W (personal care) 

b. EPS 6-10W (e.g. tablets, smart phones etc.) 

3 

4 

3 

3 

4 

3 

73 

Lifetime (years) 

2030 

3.5 

4 

5 

2035 

3.5 

4 

5 

2040 

3.5 

4 

5 

 
 
  
  
c.  EPS  10-12W  (e.g.  small  network  equipment, 
set-top boxes)  
d.  EPS  15-20W  (e.g.  portable  devices,  portable 
game consoles) 
dd. EPS 15W (personal care) 

e. EPS 20-30W (e.g. notebook computer) 

(e.g.  high-end  notebook 

f.  EPS  30-65W  multiple-V  (e.g.  multi-device 
univ. chargers) 
g.  EPS  30-65W 
computers) 
h.  EPS  65-120W 
computers) 
i. EPS 65-120W multiple-V (e.g. stationary game 
consoles) 
j.  EPS  12-15W 
systems) 
kk. Wireless chargers 

(e.g.  high-end  notebook 

loudspeakers,  sound 

(e.g. 

ll. EPS 9 W (for standard-cell battery chargers) 

mm.  Internal  power  circuitry  (in  standard-cell 
table-top battery chargers) 

4 

3 

4 

5 

5 

5 

5 

5 

5 

4 

3 

4 

5 

5 

5 

5 

5 

5 

4.5 

6 

6 

4.5 

6 

6 

4 

5 

4 

6.5 

5 

6.5 

6.5 

5 

5 

4.5 

6 

6 

4 

5 

4 

7.5 

5 

7.5 

7.5 

5 

5 

4.5 

6 

6 

4 

5 

4 

7.5 

5 

7.5 

7.5 

5 

5 

4.5 

6 

6 

Table 24: Lifetime BAU. EPS and related products. 2020-2040 

Sales data 

Sales figures  are a result of  the stock model combined with  the lifetime data and forecasts. 
Resulting sales forecast is presented in Table 25. 

For standard-cell battery chargers EBPA reports a sales figure of 1.6 million units in 2022 for 
EU-27. The model relies on the following estimations: 

•  Share wall-plugged: 25% 
•  Share  220V-wired  (and  thus  subject  to  the  externalisation  requirement,  see  options 

below): 25% 

•  Share already compatible with USB-EPS (i.e. assumed sold without EPS): 25% 
•  Share with conventional EPS: 25% 

Base case ll represents those EPS for chargers, which are not yet USB-EPS. USB-EPS used 
with standard-cell battery chargers are included in other base cases. Base case mm covers the 
internal power circuitry of those table-top chargers, which are directly powered from 220V, 
i.e. ¼ of the chargers market. Forecast until 2040 is an estimated constant sales figure of 1.6 
million  chargers  in  the  EU-27,  thereof  ¼  as  wall-plugged  units.    Assumed  lifetime  of 
chargers is 6 years. 

Sales (mln. units), year 

Base Case 

a. EPS ≤ 6W low-V (e.g. mobile phone) 

aa. EPS ≤ 6W (personal care) 

2020 

39.33 

15.00 

b. EPS 6-10W (e.g. tablets, smart phones etc.) 

205.56 

c. EPS 10-12W (e.g. small network equipment,  
set-top boxes)  
d. EPS 15-20W (e.g. portable devices, portable 
game consoles) 
dd. EPS 15W (personal care) 

147.26 

2025 

29.14 

20.00 

157.52 

149.29 

2030 

15.51 

22.00 

41.73 

2035 

6.59 

24.00 

37.37 

2040 

2.92 

26.00 

31.60 

150.38 

151.31 

152.25 

48.23 

109.29 

126.16 

136.62 

146.95 

5.00 

10.00 

12.00 

14.00 

16.00 

74 

 
 
 
  
e. EPS 20-30W (e.g. notebook computer) 

f.  EPS  30-65W  multiple-V  (e.g.  multi-device 
univ. chargers) 
g.  EPS  30-65W  (e.g.  high-end  notebook 
computers) 
h.  EPS  65-120W  (e.g.  high-end  notebook 
computers) 
i.  EPS  65-120W  multiple-V  (e.g.  stationary 
game consoles) 
j.  EPS  12-15W  (e.g. 
systems) 
kk. Wireless chargers 

loudspeakers,  sound 

13.58 

0.85 

12.80 

1.82 

9.38 

2.55 

7.53 

3.50 

6.91 

4.43 

0.49 

2.08 

2.97 

3.27 

3.28 

4.38 

2.83 

0.84 

0.00 

0.00 

3.42 

2.40 

2.42 

2.43 

2.43 

25.35 

26.43 

26.63 

26.71 

26.71 

21.73 

35.00 

0.40 

56.37 

0.40 

90.78 

0.40 

90.78 

0.40 

ll. EPS 9 W (for standard-cell battery chargers) 

0.40 

Totals 

mm.  Internal  power  circuitry  (in  standard-cell 
table-top battery chargers) 

530.59 

559.01 

469.34 

504.52 

510.67 

0.40 

0.40 

0.40 

0.40 

0.40 

Table 25 - Sales forecast BAU. EPS and related products. 2020-2040 

Assumptions in relation to the Radio Equipment Directive 

The following matrix provides an overview of the base cases which mainly contain products 
already  covered  indirectly  by  the  interoperability  requirements  of  the  Radio  Equipment 
Directive, and of those base cases which are not yet subject to interoperability requirements. 
Some of the latter are covered by the policy measure on interoperability, others are excluded 
from the interoperability scope. 

Base Case 

a. EPS ≤ 6W low-V (e.g. mobile phone) 

aa. EPS ≤ 6W (personal care) 

b. EPS 6-10W (e.g. tablets, smart phones 
etc.) 
c.  EPS  10-12W  (e.g.  small  network 
equipment, set-top boxes)  
d.  EPS  15-20W  (e.g.  portable  devices, 
portable game consoles) 
dd. EPS 15W (personal care) 

e. EPS 20-30W (e.g. notebook computer) 

in scope (indirectly) of 
RED interoperability 
requirements 

newly in scope under 
potential ecodesign 
interoperability 
requirements 

out of scope of 
interoperability 
requirements 

x 

x 

x 

x 

x 

x 

x 

x 

x 

x 

f.  EPS  30-65W  multiple-V  (e.g.  multi-
device univ. chargers) 
g.  EPS  30-65W  (e.g.  high-end  notebook 
computers) 
h. EPS 65-120W (e.g. high-end notebook 
computers) 
i.  EPS  65-120W  multiple-V 
stationary game consoles) 
j. EPS 12-15W (e.g. loudspeakers, sound 
systems) 
ll.  EPS  9W  (for  standard-cell  battery 
chargers) 
Table 26 - EPS already in scope (indirectly) of RED interoperability requirements, newly in scope under potential ecodesign 
interoperability requirements, and out of scope of interoperability requirement under both RED and potentially ecodesign, 
as represented by the base cases. NB: these represent a market segment under which, for simplifying the modelling, a range 
of products are covered, and should not be mistakenly interpreted as defining the scope of any given regulatory requirement. 

(e.g. 

x 

x 

x 

75 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Regarding stock and sales,  the following table provides  an overview  the  market  shares that 
might be subject to new interoperability requirements. 

2025 

2030 

2035 

2040 

Stock 

in scope (indirectly) of RED interoperability requirements 

49% 

46% 

42% 

42% 

in  scope  under  potential  ecodesign 

newly 
requirements 

interoperability 

38% 

36% 

33% 

33% 

out of scope of interoperability requirements under both RED and 
potentially ecodesign 

6% 

6% 

7% 

7% 

Sales 

in scope (indirectly) of RED interoperability requirements 

56% 

42% 

38% 

38% 

in  scope  under  potential  ecodesign 

newly 
requirements 

interoperability 

32% 

39% 

37% 

36% 

out of scope of interoperability requirements under both RED and 
potentially ecodesign 

5% 

7% 

8% 

8% 

Table 26: Market share of EPS already in scope (indirectly) of RED interoperability requirements, newly in 
scope under potential ecodesign interoperability requirements, and out of scope of interoperability 
requirements under both RED and potentially ecodesign 

Fuel consumption for electricity generation 

The fuel use avoided per MWh of electricity use avoided has been calculated from the energy mix of the 
PRIMES reference scenario. The resulting figures by fuel type and in total are shown in Table 27 

Table 27below. 

Table 27 - Fuel combustion per MWh electricity 

Employment  

76 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
To provide an impact of the scale of employment impacts of the policy options considered a 
simple approach is to assume that the impact of the measures on employment is proportional 
to  the  impact  on  turnover  by  each  economic  sector.  While  this  approach  fails  to  capture 
interactions between sectors and is an over-simplification it is considered adequate.  

To  indicate  the  likely  scale  of  employment  related  to  EPS  manufacture  for  the  EU  market, 
data from  a leading EPS supplier indicates an output of roughly 43,000 EPS per employee. 
For  the  EU  sales  figures  above  this  means  approximately  11,500  employees  in  the  EPS 
manufacturing  industry  related  to  EU  sales.  The  vast  majority  of  these  employees  are 
employed  in  manufacturing  outside  the  EU  and a  very  small  share  of  R&D,  administration 
and sales employment is in the EU. 

The key impacts of the policy options on employment will be seen in the electricity supply, 
retail  sectors  and the whole economy.  To assess  the scale of these, figures for employment 
and  turnover  by  NACE  sector  are  taken  from  Eurostat.  Table  28  shows  the  relevant 
employment intensities: 

Employment per €mln turnover 
All NACE 
NACE C Manufacturing 
NACE D Electricity. gas. steam and air conditioning 
supply 
NACE G Retail 
NACE G47.5.4 Retail electrical 

Table 28 - Employment intensity by turnover 

4.8 
3.6 

0.7 
3.0 
4.4 

Based on these employment intensities an estimate of the likely effect on EU employment in 
electricity supply and retail as well as changes in the overall EU economy due to increased 
consumer purchasing power can be calculated. 

4.  Consideration  of  impacts  of  EPS  harmonisation  and  voluntary  unbundling  on 

consumers and economic operators  

Harmonisation  of  the  EPS  will  likely  have  impacts  on  consumers  and  economic  operators. 
Given current trends in the market it is assumed that manufacturers will voluntary unbundle 
products and EPS once EPSs are interoperable and widely available and in use in households. 
This observation is made for the smartphone market and some other markets (gadgets being 
sold  without  EPS  but  being  chargeable  through  USB),  but  can  be  expected  to  be  business 
practice once manufacturers can rely on the existence of USB EPS in households. 

The expected extended use lifetime of interoperable and voluntary unbundling of EPS is 1.5 
times  the  product  lifetime  for  all  relevant  product  segments.  This  factor  is  derived  from  a 
representative  consumer  survey  as  part  of  the  Impact  Assessment  Study  to  Assess 
Unbundling of chargers asking for the willingness to purchase a device without EPS, in case 
an unbundled version is  available, and the intention to  purchase a stand-alone EPS with  an 
unbundled product. Stand-alone EPS sales result in a measurable rebound effect. However, in 
average the consumer survey findings indicate that one out of two EPS will be reused for a 
second product use, resulting in a calculated average 50% longer EPS lifetime.  

77 

 
 
 
For  the  data  model  the  number  of  EPS  in  stock  is  assumed  to  remain  the  same  as  a 
conservative  assumption  as  several  products  in  practice  might  share  the  same  EPS.  The 
modelled  effect  is  solely  the  effect  of  reusing  an  EPS  for  another  following  product  with 
compatible  power  requirements.  The  sales  figures  per  Base  Case  are  modelled  to  decline 
accordingly as an effect of same stock. longer lifetime. 

The  stock  model  established  by  the  Impact  Assessment  Study  to  Assess  Unbundling  of 
Chargers  indicates  that  the  EPS  use  lifetime  will  be  extended  by  50%  in  average.  Lifetime 
extension  for  EPS  for  mobile  phones  /  smartphones  and  tablets  is  slightly  more  than  these 
50% as these devices are also forecasted to be used longer given the Ecodesign and Energy 
Label requirements recently adopted. A 50% lifetime extension is also a plausible assumption 
for EPS for small ICT devices under the Radio Equipment Directive, such as digital cameras, 
fitness trackers, smart watches, bluetooth loudspeakers and similar as they all feature similar 
charging power requirements and will benefit from interoperable chargers, i.e. EPS. 

• 

in the central scenario EPS reuse is done in 1 out of 2 cases, i.e. EPS use lifetime is 
in average extended by a factor 1.5. 

As  the  actual  consumer  willingness  to  purchase  products  without  EPS,  to  reuse  existing 
EPSs,  and  the  manufacturers  business  strategy  to  provide  products  without  EPS  is  based 
solely on surveys and observations in some selected markets the assumption of a 50% longer 
use lifetime for each EPS is subject to some uncertainty. A sensitivity analysis assumes that  

• 

• 

in  a  worst-case  scenario  EPS  reuse  is  done  only  in  1  out  of  4  cases,  i.e.  EPS  use 
lifetime  is  in  average  extended  by  a  factor  1.25  (i.e.  half  the  rate  assumed  in  the 
central case) 

in  a  moderate  best-case  scenario  3  out  of  4  EPSs  are  reused  once  for  a  second 
product and every EPS reuse replaces one new EPS purchase (i.e. product lifetime is 
extended  by  a  factor  of  1.75  instead  of  1.5  in  the  central  case).  This  scenario  also 
covers better the assumed effect of parallel use of an EPS in an household for several 
devices.  In  the  model  however  this  is  calculated  with  still  a  non  affected  stock,  but 
1.75times the EPS use lifetime, i.e. correspondingly lower sales figures. Technically 
an effect, where each EPS is used for multiple devices in parallel and consecutively is 
feasible, but will face constraints in daily life due to inconvenience and lost EPSs. 

Interoperability of EPS technically enables unbundling of EPS from the products they power, 
which  producers  may  then  wish  to  practice  on  a  voluntary  base.  Voluntary  unbundling  of 
EPS from the products they power allows producers high degree of control over the impacts 
on their own products and business by the degree and extent of unbundling.  

For mobile phones, most economic operators in the sector are big companies located outside 
the  EU.  and  several  of  them  already  offer  unbundling.    There  are  also  a  few  small  mobile 
phone  manufacturers  that  are  based  in  the  EU  (IA  Unbundling  2021).  Most  of  these 
manufacturers already practice voluntary unbundling, i.e. they sell their smartphones without 
EPS  -  one  manufacturer  even  without  a  cable  as  the  default  setting  -  even  though  not 
necessarily  for  all  their  models.    Voluntary  unbundling  was  also  observed  for  e-readers 
(predominantly) or digital cameras (partially). For other products than the above, unbundling 
is hardly practiced (IA Unbundling 2021).  

As  a  legally  required  harmonisation  and  respective  information  for  customers  reduces 
uncertainties as to  the interoperability of EPS, it might  encourage more customers to  select 

78 

 
 
unbundling options where offered. For products in the scope of the revised RED, which may 
require producers to offer an unbundling option. the current degree of customers opting for 
unbundling may thus increase and reduce producers’ economic benefits arising from sales of 
products with EPS. There are however no data available that would allow quantifying these 
impacts for producers.  

Producers of products outside the RED but within the scope of the revised directive who so 
far  have  not  offered  unbundling  might  be  incentivized  to  offer  their  products  without  EPS 
voluntarily, or customers may ask them to offer it. Improved interoperability and information 
might motivate customers to choose these options. which would reduce producers’ economic 
profits.  As unbundling would be voluntary for these producers, it can be assumed that they 
would  avoid  unbundling  beyond  a  degree  where  it  might  have  severe  impacts  on  their 
business.  

Manufacturers  of  EPS  would  be  affected  if  the  number  of  EPS  sold  decreases.  For 
telecommunication, around 100 companies manufacture power supply units with an estimate 
turnover  in  2020  of  154  million  EUR  including  only  turnover  from  sales  of  chargers.  On 
average, there were around 1900 people in the EU employed in the production of chargers. 
Unbundling reducing the number of EPS sales affects the firms’ turnover and therefore may 
have wider macroeconomic implications on production and employment. However, given the 
small size of the market, the significance of the impact on employment in the EU would be 
low (IA Unbundling 2021). 

Unbundling  will  probably  also  affect  traders.  They  generate  their  incomes  from  profit 
margins  in  relation  to  product  prices,  and  these  profits  would  decrease  provided  that  ErPs 
sold without EPS are cheaper than those sold with EPS. A minor portion of these losses may 
be  compensated  by  higher  sales  of  separate  EPS.  There  are  however  no  data  available  to 
quantify these impacts for traders. 

5.  Modelling Data for the Assessment of Policy Measures and resulting Policy Options 

M1 - Scope extension 

As  certain  options  to  extend  the  scope  to  EPS,  such  as  those  for  charging  e-bikes  and  for 
lighting  products,  were  omitted  after  further  evaluation,  and  as  the  effect  on  some  other 
products depends on the mandatory externalisation of the power circuitry, the sole extension 
of the scope does not change any stock model assumptions. 

M2 - Requiring compatibility with USB-PD specifications to increase interoperability 

EPS powering RED devices are already  (indirectly) required to be  USB compatible. Under 
M2a  they  are  subject  only  to  additional  information  requirements  which  are  discussed  in 
Section 8.6.  

Under M2b, the expected extended use lifetime of interoperable EPS is 1.5 times the initially 
assumed product lifetime for all relevant product segments as shown in Table 29. 

The number of EPS in stock is assumed to remain the same as a conservative assumption, as 
several  products  in  practice  might  share  the  same  EPS.  The  modelled  effect  is  solely  the 

79 

 
 
 
 
 
 
 
 
effect of reusing an EPS for another following product with compatible power requirements. 
The sales figures per Base Case are modelled to decline accordingly as an effect of the same 
stock at longer lifetime. 

Base Case 

2020 

2025 

a. EPS ≤ 6W low-V (e.g. mobile phone) 

aa. EPS ≤ 6W (personal care) 

b. EPS 6-10W (e.g. tablets, smart phones etc.) 

c.  EPS  10-12W 
(e.g. 
equipment, set-top boxes)  
d.  EPS  15-20W 
portable game consoles) 
dd. EPS 15W (personal care) 

small  network 

(e.g.  portable  devices, 

e. EPS 20-30W (e.g. notebook computer) 

f.  EPS  30-65W  multiple-V  (e.g.  multi-device 
univ. chargers) 
g.  EPS  30-65W  (e.g.  high-end  notebook 
computers) 
h.  EPS  65-120W  (e.g.  high-end  notebook 
computers) 
i.  EPS  65-120W  multiple-V  (e.g.  stationary 
game consoles) 
j.  EPS  12-15W  (e.g.  loudspeakers,  sound 
systems) 
kk. Wireless chargers 

ll.  EPS  60W  (e.g.  power  tools,  gardening 
tools) 
mm.  Internal  power  circuitry  (e.g.  EPS  for 
power tools, gardening tools) 

3 

4 

3 

4 

3 

4 

5 

5 

5 

5 

5 

5 

3 

4 

3 

4 

3 

4 

5 

5 

5 

5 

5 

5 

4.5 

4.5 

6 

6 

6 

6 

Lifetime (years) 

2030 

3.5 

2035 

3.5 

2040 

3.5 

5 

5 

6 

5 

5 

6.5 

6.5 

6.5 

6.5 

6.5 

6.5 

4.5 

7.5 

6 

6 

5 

6 

5 

6 

7.5 

7.5 

7.5 

7.5 

7.5 

7.5 

4.5 

9 

6 

6 

5 

6 

5 

6 

7.5 

7.5 

7.5 

7.5 

7.5 

7.5 

4.5 

9 

6 

Table 29 - Lifetime M2 (where applicable) 

Implementing  USB  results  in  additional  losses  due  to  the  USB  receptacles  and  cable, 
compared  to  conventional  2-wire  DC  cable:  For  the  EPS,  an  additional  USB  receptacle 
resistance  of  40mOhm  and  an  additional  USB  cable  (wires  only)  resistance  of  80mOhm 
compared  to  a  replaced  hard-wired  2-wire  cable  resistance  of  35mOhm  (20AWG,  0.5mm2) 
results in a total additional resistance of 85mOhm. On the end device side, a 40mOhm USB 
receptacle  has  to  be  fitted  instead  of  a  20mOhm  barrel  connector.  This  results  in  a  total 
additional resistance of 105mOhm.  The additional losses in W are calculated based on this 
resistance, and the power output modelled at low load and active load due to the assumed use 
profiles. 

For table-top battery chargers implementing USB results in additional losses due to the USB 
receptacles  and  cable,  compared  to  conventional  2-wire  AC  cable:  For  the  EPS  an  USB 
receptacle  resistance  of  40mOhm  and  a  USB  cable  resistance  of  80mOhm  compared  to  a 
replaced  hard-wired  2-wire  cable  resistance  of 18mOhm  (17AWG, 1mm2) results in  a total 
additional  resistance  of  102mOhm.  On  the  end  device  side  another  USB  receptacle  with  a 
resistance of 40mOhm  has  to  be implemented instead of  a 20mOhm  barrel  connector. This 
results in a total additional resistance of 122mOhm.   

The calculated additional electrical losses are shown in Table 30. 

80 

 
 
 
  
 
Additional power consumption due to USB implementation 

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5 

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5 

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Base Case 
a.  EPS  ≤  6  W  low-V  (e.g. 
mobile phone) 

aa. EPS ≤ 6 W (personal care) 
b.  EPS  6-10  W  (e.g.  tablets, 
smart phones etc.) 
c.  EPS  10-12  W  (e.g.  small 
network 
set-top 
equipment, 
boxes)  
d.  EPS  15-20  W  (e.g.  portable 
game 
devices, 
consoles) 

portable 

dd. EPS 15 W (personal care) 
e. EPS 20-30 W (e.g. notebook 
computer) 
f.  EPS  30-65  W  multiple-V 
(e.g. 
univ. 
multi-device 
chargers) 
g. EPS 30-65 W (e.g. high-end 
notebook computers) 
h.  EPS  65-120  W  (e.g.  high-
end notebook computers) 
i.  EPS  65-120  W  multiple-V 
(e.g. stationary game consoles) 
j.  EPS 
(e.g. 
loudspeakers. sound systems) 

12-15  W 

kk. Wireless chargers 
ll.  EPS  9  W  (for  standard-cell 
battery chargers) 

Table 30 – M2 - Additional power losses due to USB implementation 

M2b assumes the following additional costs:  

81 

 
 
 
 
 
 
 
   
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
•  €0.60  due  to  the  required  surge  protection  design  changes  to  make  all  interoperable 

EPS meet the requirements of network equipment. 

•  €1.50 for adaptation to the USB-C receptacle and USB-PD circuitry37. 
•  €1 for the shift from an existing cable and connector to a USB cable38. 

The  discarded  interoperability  measure  for  wet-use  EPS  considered  an  additional  cost  of 
€2.00 for all interoperable EPS due to the required IPx4 protection level. 

Information requirements: the effect of an interoperability marking on the EPS is considered 
a means of information  complementing the RED requirements and providing further clarity 
on  compatible  product  –  EPS  combinations,  but  as  the  effect  on  the  market  cannot  be 
quantified  and  the  additional  burden  to  add  related  markings  on  the  product  is  considered 
minor, no changes to the stock model are implemented under measure M2a or M2b. 

An information requirement on energy efficiency on the EPS nameplate has been discarded 
to avoid coherence issues with the DoE requirements, as the testing at different grid voltages 
may lead to slightly different results for the same product.  

M3 - Minimum energy efficiency at 10% load 

A minimum requirement set at 10%pt below current average active efficiency (policy option 
M3a)  actually  means  banning  very  few  outliers  resulting  in  marginal  improvements.  It  is 
expected that such a requirement increases efficiency at this load-point across the market by 
0.04%pt at negligible costs. 

M3b foresees a low-load threshold 6%pt below the revised active average efficiency defined 
under M4a, for EPS with an output power higher than 10W. Based on market statistics and 
adaptation of the cost analysis carried out by the US Department of Energy on EPS costs in 
relation  to  power  consumption  levels,  efficiency  and  cost  parameters  per  Base  Case  are 
modelled with the data provided in Table 31 for M3a and M3b. 

Base Case 

Measure M3a 

Measure M3b 

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t
i
n
g

e
f
f
i
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n
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y
g
a
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n

c
o
m
p
l
i
a
n
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u
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t

c
o
s
t

i
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c
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a
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p
e
r
n
o
n
-

m
a
r
k
e
t

c
o
s
t

i
n
c
r
e
a
s
e
a
c
r
o
s
s

t
h
r
e
s
h
o
l
d

m
a
r
k
e
t

s
h
a
r
e
b
e
l
o
w

a
c
r
o
s
s

m
a
r
k
e
t

r
e
s
u
l
t
i
n
g

e
f
f
i
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e
n
c
y
g
a
i
n

c
o
m
p
l
i
a
n
t
u
n
i
t

c
o
s
t

i
n
c
r
e
a
s
e
p
e
r
n
o
n
-

m
a
r
k
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t

c
o
s
t

i
n
c
r
e
a
s
e
a
c
r
o
s
s

a.  EPS  ≤  6W.  low-V  (e.g. 
mobile phone) 
aa. EPS ≤ 6W (personal care) 

b.  EPS  6-10W  (e.g.  tablets. 
smart phones etc.) 

100.0%  2.2% 

0.04 € 

0.04 €  N/A 

0.0% 

0.00 € 

0.00 € 

100.0%  2.2% 

0.04 € 

0.04 €  N/A 

0.0% 

0.00 € 

0.00 € 

100.0%  2.1% 

0.05 € 

0.05 €  N/A 

0.0% 

0.00 € 

0.00 € 

37 based on component costs identified in the Common Charger Impact Assessment Study, where a range from 
€0.60  to  €2.40  for  USB  components  has  been  identified  (p.  99),  and  on  additional  estimates  by  industry, 
expecting roughly a €2 price difference for a 30W USB-PD EPS vs. a similar non-USB EPS. 
38 According to data from the Common Charger IA study a USB cable costs 1.5€ when sold in the box, which 
replaces a conventional EPS cable (2-wire DC cable), thus arriving at a cost difference of 1€. 

82 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
c.  EPS  10-12W  (e.g.  small 
network  equipment.  set-top 
boxes)  
d.  EPS  15-20W  (e.g.  portable 
devices. 
game 
consoles) 
dd. EPS 15W (personal care) 

portable 

e. EPS 20-30W (e.g. notebook 
computer) 
f.  EPS  30-65W.  multiple-V 
(e.g.  multi-device 
univ. 
chargers) 
g. EPS 30-65W (e.g. high-end 
notebook computers) 
h.  EPS  65-120W  (e.g.  high-
end notebook computers) 
i.  EPS  65-120W.  multiple-V 
(e.g. 
game 
stationary 
consoles) 
(e.g. 
EPS 
j. 
loudspeakers. sound systems) 
kk. Wireless chargers 

12-15W 

ll. EPS 9 W (for  standard-cell 
battery chargers) 

72.7% 

2.8% 

0.07 € 

0.04 € 

72.7% 

2.8% 

0.07 € 

0.04 € 

56.4% 

1.2% 

0.14 € 

0.06 € 

56.4% 

1.2% 

0.14 € 

0.06 € 

56.3% 

1.2% 

0.12 € 

0.07 € 

56.3% 

1.2% 

0.12 € 

0.07 € 

32.1% 

1.1% 

0.24 € 

0.08 € 

32.1% 

1.1% 

0.24 € 

0.08€ 

17.8% 

0.5% 

0.48 € 

0.09 € 

17.8% 

0.5% 

0.48 € 

0.09 € 

17.8% 

0.6% 

0.48 € 

0.09 € 

17.8% 

0.6% 

0.48 € 

0.09 € 

10.1% 

0.4% 

0.80 € 

0.08 € 

10.1% 

0.4% 

0.80 € 

0.08 € 

10.1% 

0.4% 

0.80 € 

0.08 € 

10.1% 

0.4% 

0.80 € 

0.08 € 

81.3% 

2.2% 

0.09 € 

0.07 € 

81.3% 

2.2% 

0.09 € 

0.07 € 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

100.0%  1.8% 

0.05 € 

0.05 €  N/A 

0.0% 

0.00 € 

0.00 € 

Table 31: M3 - Low load efficiency and costs (where applicable) 

M4 - Raising the minimum requirement on active average efficiency  

and limiting stand-by losses for wireless chargers 

Current  average  active  efficiency  requirements  are  listed  below  in  comparison  to  those 
analysed by US Department of Energy as candidates for Level VII. 

AC-AC 
external 
power supplies. except 
low 
and 
voltage 
multiple 
voltage 
output external power 
supplies 

external 
AC-DC 
power 
supplies. 
except  low  voltage 
and multiple voltage 
external 
output 
power supplies 

Low 
voltage 
external  power 
supplies 

Multiple  voltage 
output  external 
power supplies 

PO ≤ 1.0W 

0.5 × PO/1W+ 0.160 

0.5 × PO/1W+ 0.160 

0.517 
PO/1W+ 0.087 

× 

0.497  ×  PO/1W+ 
0.067 

1  W  <  PO  ≤ 
49.0 W 

0.071  ×  ln(PO/1W)  – 
0.0014 × PO/1W+ 0.67 

0.071  ×  ln(PO/1W)  – 
0.0014  ×  PO/1W+ 
0.67 

0.0834 
ln(PO/1W) 
0.0014 
Po/1W+ 0.609 

× 
– 
× 

0.075 
ln(PO/1W) 
0.561 

× 
+ 

PO > 49.0W 

0.880 

0.880 

0.870 

0.860 

2
8
7
1
/
9
1
0
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)

U
E

(
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a
4
M

b
4
M

S
U

-

PO ≤ 1.0W 

0.5 × PO/1W+ 0.169 

0.5 × PO/1W+ 0.169 

1  W  <  PO  ≤ 
49.0W 

0.0582  ×  ln(PO/1W)  – 
0.00104  ×  PO/1W+ 
0.727 

0.071  ×  ln(PO/1W)  – 
0.00115  ×  PO/1W+ 
0.67 

0.517 
PO/1W+ 0.091 

× 

0.497  ×  PO/1W+ 
0.067 

0.0834 
ln(PO/1W) 
0.0011 
Po/1W+ 0.609 

× 
– 
× 

× 
0.0782 
ln(PO/1W) 
– 
0.0013  ×  Po/1W 
+ 0.643 

PO > 49.0W 

0.902 

0.890 

0.880 

0.885 

PO ≤ 1.0W 
%
0
5

p
o
  T
2

L
S
C

E
o
D

0.5 × PO/1W+ 0.169 

0.517 
× 
PO/1W+ 0.091  

0.497  x  PO/1W  + 
0.067 

83 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
1  W  <  PO  ≤ 
49.0W 

PO > 49.0W 

PO ≤ 1.0W 

1  W  <  PO  ≤ 
49.0W 

0.0617  ×  ln(PO/1W) 
– 0.00105 × PO/1W+ 
0.704 

0.0741 
ln(PO/1W) 
0.00105 
PO/1W+ 0.643 

× 
– 
× 

× 
0.0782 
ln(PO/1W) 
– 
0.0013  ×  Po/1W 
+ 0.643 

0.895 

0.885 

0.885 

0.5 × PO/1W+ 0.169 

0.517 
× 
PO/1W+ 0.091  

0.497  x  PO/1W  + 
0.067 

0.0582  ×  ln(PO/1W) 
– 0.00104 × PO/1W+ 
0.727 

0.0706 
ln(PO/1W) 
0.00104 
PO/1W+ 0.666 

× 
– 
× 

× 
0.0861 
ln(PO/1W) 
– 
0.00169  ×  Po/1W 
+ 0.642 

PO > 49.0W 

0.902 

0.892 

0.895 

3
L
S
C
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o
D
S
U

-

c
4
M

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e
k
r
a
M
n
I

t
s
e
B

Table 32: Active average efficiency requirements: as per Regulation (EU) 2019/1782; M4a - aligned with US 
DoE CSL1; M4b - aligned with CSL2; M4c - aligned with CSL3 

Modelling costs and use phase impacts of M4a, M4b and M4c are provided in Table 33 and 
Table 34. 

Base Case 

Average active efficiency 

Policy  measure  M4a  (US  DoE 
CSL1) 

Policy measure M4b (US DoE CSL2) 

m
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e

2% 

0.04 € 

0.00 € 

0.01% 

2.0% 

50% 

0.25 € 

0.13 € 

0.50% 

2% 

2% 

0.06 € 

0.00 € 

0.01% 

2.0% 

50% 

0.26 € 

0.13 € 

0.50% 

0.05 € 

0.00 € 

0.01% 

2.0% 

50% 

0.26 € 

0.13 € 

0.50% 

5% 

0.06 € 

0.00 € 

0.03% 

1.5% 

50% 

0.27 € 

0.14 € 

0.38% 

10% 

0.08 € 

0.01 € 

0.05% 

1.3% 

50% 

0.30 € 

0.15 € 

0.33% 

a.  EPS  ≤  6W  low-V  (e.g.  mobile 
phone) 

aa. EPS ≤6 W (personal care) 

b.  EPS  6-10W  (e.g.  tablets,  smart 
phones etc.) 

c. EPS 10-12W (e.g. small network 
equipment, set-top boxes)  

d.  EPS  15-20W  (e.g.  portable 
devices, portable game consoles) 

dd. EPS 15W (personal care) 

10% 

0.06 € 

0.01 € 

0.05% 

1.4% 

50% 

0.28 € 

0.14 € 

0.35% 

e.  EPS  20-30W  (e.g.  notebook 
computer) 

f.  EPS  30-65W  multiple-V  (e.g. 
multi-device univ. chargers) 

g.  EPS  30-65W  (e.g.  high-end 
notebook computers) 

h.  EPS  65-120W  (e.g.  high-end 
notebook computers) 

i.  EPS  65-120W  multiple-V  (e.g. 
stationary game consoles) 

10% 

0.11 € 

0.01 € 

0.05% 

1.3% 

50% 

0.32 € 

0.16 € 

0.33% 

30% 

0.40 € 

0.12 € 

0.15% 

1.4% 

50% 

0.72 € 

0.36 € 

0.35% 

30% 

0.14 € 

0.04 € 

0.15% 

1.4% 

50% 

0.31 € 

0.16 € 

0.35% 

30% 

0.20 € 

0.06 € 

0.15% 

1.5% 

50% 

0.29 € 

0.14 € 

0.38% 

30% 

0.49 € 

0.15 € 

0.15% 

1.5% 

50% 

0.67 € 

0.34 € 

0.38% 

84 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
j.  EPS  12-15W  (e.g.  loudspeakers. 
sound systems) 

10% 

0.05 € 

0.01 € 

0.05% 

1.4% 

50% 

0.28 € 

0.14 € 

0.35% 

kk. Wireless chargers 

N/A  N/A 

N/A 

N/A 

N/A 

N/A  N/A 

N/A 

N/A 

ll.  EPS  9  W  (for  standard-cell 
battery chargers) 

2% 

0.05 € 

0.00 € 

0.01% 

2.0% 

50% 

0.26 € 

0.13 € 

0.50% 

Table 33: No-load efficiency and average active efficiency - Incremental costs per unit -  policy measures M4a 
and M4b 

Base Case 

Average active efficiency 

No-load 

Policy measure M4.c (US DoE CSL3) 

Policy 
measures  M4a, 
M4b, M4c 

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s

a. EPS ≤ 6W. low-V (e.g. mobile phone) 

4.4% 

82% 

0.57 € 

0.47 € 

1.81% 

0.06 

t
o

e
x
a
c
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l
y
m
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t
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d

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e

a
s
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e
d
0.054 

aa. EPS ≤6 W (personal care) 

4.4% 

100% 

0.59 € 

0.59 € 

2.20% 

0.084 

0.071 

b. EPS 6-10W (e.g. tablets. smart phones etc.) 

3.3% 

100% 

0.60 € 

0.60 € 

1.65% 

0.067 

0.063 

c.  EPS  10-12W 
(e.g. 
equipment. set-top boxes)  

small  network 

d.  EPS  15-20W 
portable game consoles) 

(e.g.  portable  devices. 

dd. EPS 15W (personal care) 

e. EPS 20-30W (e.g. notebook computer) 

f. EPS 30-65W. multiple-V (e.g. multi-device 
univ. chargers) 

g.  EPS  30-65W  (e.g.  high-end  notebook 
computers) 

h.  EPS  65-120W  (e.g.  high-end  notebook 
computers) 

i.  EPS  65-120W.  multiple-V  (e.g.  stationary 
game consoles) 

j.  EPS  12-15W  (e.g.  loudspeakers,  sound 
systems) 

3.0% 

100% 

0.61 € 

0.61 € 

1.50% 

0.066 

0.062 

2.7% 

77% 

0.62 € 

0.48 € 

1.04% 

0.093 

0.068 

2.8% 

2.5% 

50% 

88% 

0.62 € 

0.31 € 

0.70% 

0.093 

0.068 

0.64 € 

0.56 € 

1.10% 

0.066 

0.064 

4.5% 

88% 

1.25 € 

1.10 € 

1.97% 

0.089 

0.077 

1.4% 

50% 

0.60 € 

0.30 € 

0.35% 

0.089 

0.077 

1.5% 

50% 

0.90 € 

0.45 € 

0.38% 

0.111 

0.097 

1.5% 

50% 

0.90 € 

0.45 € 

0.38% 

0.111 

0.097 

1.4% 

50% 

0.40 € 

0.20 € 

0.35% 

0.08 

0.064 

kk. Wireless chargers 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

N/A 

ll.  EPS  9  W  (for  standard-cell  battery 
chargers) 

3.3% 

100% 

0.60 € 

0.60 € 

1.65% 

0.089 

0.063 

85 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Table 34 – Incremental costs per unit - average active efficiency costs policy measure M4c and no-load 
efficiency policy measure M4a, M4b and M4c 

M4d defining a stand-by power requirement of maximum 0.48W for wireless charging pads 
is  modelled  based  on  data  from  DoE  according  to  which  70%  of  the  market  is  already  in 
compliance  with  this  requirement,  while  the  remaining  30%  have  to  improve.  Average 
additional  product  costs  across  the  whole  market  is  a  price  increase  of  €0.15  per  wireless 
charger / charging pad. 

M5 - Externalisation of power supply circuitries for battery charging devices  

and wireless chargers 

The stock of single cell battery chargers shifts over time from Base Case mm. Internal power 
circuitry  to  the  other  Base  Cases  as  a  shared  use  of  already  existing  EPS  is  assumed. 
Redesign costs for the charger have to be considered: Battery chargers with internal AC-DC 
circuitry  or  conventional  EPS  are  in  the  price  range  of  30€.  Comparable  chargers  with 
integrated  USB  logic  and  Type-C  receptacle  are  currently  sold  at  around  20€.  For  the 
modelling this means a net 10€ cost for an internal power circuitry, and thus savings of 10€ 
net for each unbundled USB-compatible charger. 

Wireless chargers are largely already placed on the market with an externalised USB power 
supply. No additional costs are assumed for this product under this measure.  

M6 - Durability 

Given that the use lifetime is not only related to the technically feasible lifetime, but also to 
use  patterns  and  other  factors  leading  to  premature  end  of  life  of  EPS  this  policy  option  is 
calculated  with  a  lifetime  extended  by  another  2  months  on  top  of  the  effect  of  M2b 
(interoperability). 

Even  with  a  requirement  of  a  10  year  technical  lifetime  the  overall  lifetime  extension 
potential  is  limited  by  factors,  which  also  lead  to  the  assumption  of  1.5  times  lifetime 
extension through interoperability:  Although  users will have the option to use existing  EPS 
for multiple powered products consecutively the consumer survey undertaken as part of the 
Unbundling Impact Assessment indicated a strong motivation to purchase a new EPS with a 
new  device.  Consequently  it  is  expected,  that  also  in  future  many  fully  functional  EPS  are 
hoarded unused, or are used interchangeably. The technical lifetime in most cases will not be 
the driving factor for replacement sales of EPS.  

Vice  versa,  the  lifetime  extending  effect  has  to  be  modelled  only  for  those  EPS  which  are 
taken out of operation due to technical defects or wear-out, which is assumed to be a minor 
share. Beyond anecdotal evidence there is no data on the share of defect EPSs. Under these 
conditions  it  is  safe  to  assume  that  the  10  year  lifetime  turns  into  actually  longer  use  of 
individual  EPSs  only  in  a  very  limited  number  of  cases.  These  considerations  justify  an 
average lifetime extension of 2 months across all EPSs. 

86 

 
 
 
 
 
 
 
 
 
 
  
The incremental cost per unit under M6 is shown in Table 35. With no changes to the EPS 
stock of EPS it is modelled to lead to decreasing sales of EPS accordingly.  

Base Case 

Product price increase (€) 

a. EPS ≤ 6W low-V (e.g. mobile phone) 

aa. EPS ≤ 6W (personal care) 

b. EPS 6-10W (e.g. tablets, smart phones etc.) 

c. EPS 10-12W (e.g. small network equipment, set-top boxes)  

d. EPS 15-20W (e.g. portable devices, portable game consoles) 

dd. EPS 15W (personal care) 

e. EPS 20-30W (e.g. notebook computer) 

f. EPS 30-65W multiple-V (e.g. multi-device univ. chargers) 

g. EPS 30-65W (e.g. high-end notebook computers) 

h. EPS 65-120W (e.g. high-end notebook computers) 

i. EPS 65-120W multiple-V (e.g. stationary game consoles) 

j. EPS 12-15W (e.g. loudspeakers, sound systems) 

kk. Wireless chargers 

ll. EPS 9 W (for standard-cell battery chargers) 

Table 35: M6 – EPS Lifetime EPS 

0.06 

0.00 

0.06 

0.06 

0.06 

0.00 

0.08 

0.10 

0.10 

0.10 

0.10 

0.06 

0.00 
not applicable39 

M6 only makes sense in conjunction with the interoperability measure M2  under which the 
additional costs and energy losses due to detachable cables have already been considered as a 
consequence  of  the  USB  requirements.  To  avoid  double  counting  they  have  not  been 
considered separately also under M6.   

Uncertainty 
As noted during the analysis there are considerable uncertainties in many of the underlying 
assumptions.  Future  projections  about  electricity  prices  and  GHG  intensity  of  electricity 
generation  are  inevitably  uncertain.  However,  their  impacts  will  simply  linearly  change  the 
value of the estimated electricity or GHG savings. 

There is also uncertainty in how to value the contribution to the different specific objectives. 
However, by testing with different weightings for the energy, emissions and materials savings 
this has been shown to not have a dramatic effect on the rankings of the policy options. 

The  biggest  uncertainty  relates  to  how  consumers  will  react  to  the  availability  of 
interoperable EPS. The sensitivity tests discussed in Annex 13 indicate the magnitude of such 
effects. The assumption that consumers will reuse and therefore choose to purchase less new 
EPS  is  central  to  the  reduced  purchase  costs  of  the  interoperability  measure  M2b.  The 
prolongation  of  the  EPS  life  also  ensures  that  the  policy  options  including  higher  energy 
efficiency deliver sufficient savings to offset the higher purchase costs. 

A  shorter  assumed  life  extension  would  have  a  much  larger  proportionate  impact  on  the 
overall benefits of the combined options. The opposite would also be true. 

39 Fully replaced by the shared use of USB-EPS covered by other base cases. 

87 

 
 
 
 
ANNEX 5: THE ECODESIGN AND ENERGY LABELLING FRAMEWORK 

The  Ecodesign  Framework  Directive  and  Energy  Labelling  Framework  Regulation  are 
framework  rules,  establishing  conditions  for  laying  down  product-specific  requirements  in 
regulations  adopted  by  the  Commission.  The  Commission's  role  in  the  implementation  of 
delegated  and  implementing  acts  is  to  ensure  a  maximum  of  transparency  and  stakeholder 
participation in presenting a proposal, based on generally accepted data and information, to 
the  European  Parliament  and  Council  for  scrutiny.  Figure  18  gives  an  overview  of  the 
procedures leading to a voluntary agreement, Ecodesign requirements or an Energy label. 

Figure 18 - Overview of the three processes 

Ecodesign  and  Energy  labelling  are  complementary.  Ecodesign  implementing  measures  lay 
down minimum energy efficiency requirements for a product group and therefore ban worse 
performing products. In contrast, energy labelling provides objective comparable information 
to enable consumers to choose better performing products through mandatory rating. In view 
of the complementarity, energy labelling delegated acts are usually adopted in parallel with 
Ecodesign implementing acts to ensure coherence between the measures. 

The  process  starts  with  establishing  the  priorities  for  Union  action  in  this  area.  Priority 
product groups are selected based on their potential for cost-effective reduction of energy use 
and  GHG  emissions  and  follows  a  transparent  process  culminating  in  a  working  plan  that 
outlines  the  priorities  for  the  development  of  implementing  measures  for  the  next  years. 
Working  plans  are  adopted  by  the  Commission  after  consultation  of  the  Ecodesign  and 
Energy labelling Consultation Forum. The forum brings together representatives of Member 
States and relevant stakeholders. The Ecodesign and Energy labelling Working plan 2022-24 
identifies EPS as a priority.  

Once  the  product  group  has  been  selected,  a  preparatory  study  is  undertaken  by  an 
independent  consultant,  also  involving  extensive  technical  discussions  with  interested 
stakeholders. The preparatory study follows the standard Methodology for the Ecodesign of 

88 

 
 
 
 
Energy Related Products (MEErP). Subsequently. the Commission's first drafts of Ecodesign 
and energy labelling measures are submitted for discussion to the Consultation Forum. 

After the Consultation Forum. the Commission drafts an impact assessment, which after RSB 
approval  accompanies  the  draft  implementing  measures  in  the  Commission’s  inter-service 
consultation.  In  this  and  subsequent  steps,  the  Parliament's  functional  mailboxes  for 
delegated/implementing  acts  are  copied  on  each  message  from  the  Commission  services. 
After  the  inter-service  consultation,  stakeholders  are  alerted  when  the  draft  measures  are 
published in the WTO (World Trade Organisation) notification database. 

After  the  WTO  notification  phase  is  completed,  the  two  procedures  follow  different  paths. 
The draft energy labelling delegated act is discussed in a Member States Expert Group where 
opinion(s) are expressed and consensus is sought but no vote is taken. The draft Ecodesign 
measure is submitted for vote to the Regulatory Committee. 

The  European  Parliament  and  Council  have  the  right  of  scrutiny  for  a  period  of  up  to  four 
months.  Within  this  time,  the  co-legislators  can  block  the  adoption  process  by  the 
Commission.  Parliament  committees  sometimes  discuss  draft  objections  to  measures  (light 
bulbs and fridges in 2009) or vote to reject a measure (vacuum cleaners in 201340). On one 
occasion. an objection was adopted in plenary, blocking the measure for televisions in 200941.  

Today, 30 Ecodesign Regulations, 15 Energy Labelling Regulations. 2 voluntary agreements 
and  2  tyre  labelling  regulations  have  been  implemented.  An  overview  of  the  measures  in 
force is available on the Europa website. 

The Market Surveillance Regulation42 establishes the rules on Union market surveillance and 
control  of  products  entering  the  Union  market.  Market  Surveillance  Authorities  (MSAs). 
designated  by  Member  States.  will  verify  the  conformity  of  the  products  with  the 
requirements  laid  down  in  the  implementing  measures  and  delegated  acts.  Checks  can  be 
done on the product itself or by verifying the technical documentation.  

40 This objection was defeated in ENVI committee by 43 votes against and 4 in favour. 
41 The motivation of the objection was that the EP wanted to delay the discussion of the draft labelling measure 
so  that  it  would  have  to  become  a  delegated  act  under  the  recast  post-Lisbon  Energy  Labelling  Directive  in 
2010. The measure was subsequently adopted as a delegated act. 
42 Regulation (EC) No 765/2008 of the European Parliament and of the Council of 9 July 2008 setting out the 
requirements  for  accreditation  and  market  surveillance  relating  to  the  marketing  of  products  and  repealing 
Regulation (EEC) No 339/93 OJ L 218, 13.8.2008, p. 30. 

89 

 
 
 
 
 
ANNEX 6: PRODUCTS IN SCOPE OF THE CURRENT EPS REGULATION  

EPS are devices used to supply electricity to, and to charge built-in batteries of electronic and 
electric devices ("primary load products") such as laptops, mobile phones, tablets and electric 
shavers43.  For  other  products  without  built-in  batteries.  they  serve  as  the  main  continuous 
source of power – for example standalone loudspeakers or computer network equipment such 
as modems and routers. The use of such products spans both domestic and office settings. An 
EPS  transforms  the  voltage  supplied  by  an  electric  socket  normally  at  230V  to  a  lower 
voltage level suitable to the primary load product – often between 5V and 20V.  

An EPS also  often rectifies the Alternating Current  (AC) from the  electric socket to  Direct 
Current  (DC)  typically  used  for  portable  electric  and  most  electronic  products.  It  may  also 
contain  intelligent  electronics  to  enable  fast  charging  cycles  and  to  avoid  detrimental  over-
charging of built-in batteries. The figure below shows examples of typical EPS types: 

Figure 19 - Pictures of typical EPS types. Source: EPS manufacturers 

(EU)  2019/1782  establishing  minimum  efficiency 
COMMISSION  REGULATION 
requirements for external power supplies was adopted on 1 October 2019. Its scope44 covers 
EPS that meet all of the following criteria:  

•  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;  

•  used with one or more separate devices that constitute the primary load;  

43 The EPS are not the same as battery chargers, which charge batteries in isolation (extracted from the product), 
and are exempted from the scope of the Ecodesign Regulation. 
44  The  stated  scope  explicitly  excludes  battery  chargers  (that  connect  directly  to  removable  batteries), 
uninterruptable power supplies (e.g. the ones used in data centres and enterprise server rooms for maintaining 
continuity of power supply to computers and servers), voltage converters (e.g. 230V to 110V travel adapters), 
converters used for halogen lighting and EPS for medical devices. Uninterruptable power supplies and halogen 
lighting converters are addressed in other product specific regulations. 

90 

 
 
 
 
 
•  contained in a physical  enclosure separate from the device or devices that constitute 

the primary load;  

•  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;  

•  a nameplate output power not exceeding 250 watts; and  

•  used with electrical and electronic household and office equipment included in Annex 

I of the Regulation  

Annex  I of the Regulation  lists  the following  electrical  and electronic household  and office 
equipment applications of EPS to be in scope: 

1. Household appliances: 

•  Appliances for cooking and other processing of food. preparing beverages. opening or 

sealing containers or packages. cleaning. and maintenance of clothes. 

•  Appliances  for  hair  cutting,  hair  drying,  hair  treatment.  tooth  brushing,  shaving, 

massage and other body care appliances. 

•  Electric knives. 

•  Scales. 

•  Clocks. watches and equipment for the purpose of measuring, indicating or registering 

time. 

2. Information technology equipment. including copying and printing equipment, and set-top 
boxes, intended primarily for use in the domestic environment. 

3. Consumer equipment: 

•  Radio sets. 

•  Video cameras. 

•  Video recorders. 

•  Hi-fi recorders. 

•  Audio amplifiers. 

•  Home theatre systems. 

•  Televisions. 

•  Musical instruments. 

•  Other  equipment  for  the  purpose  of  recording  or  reproducing  sound  or  images. 
including signals or other technologies for the distribution of sound and image other 
than by telecommunications. 

4. Electrical and electronic toys. leisure and sports equipment: 

•  Electric trains or car racing sets. 

•  Game consoles. including hand-held game consoles. 

•  Sports equipment with electric or electronic components; 

•  Other toys. leisure and sports equipment. 

91 

 
 
ANNEX 7: EVALUATION OF REGULATION (EU) 2019/1782 ON ECODESIGN 
REQUIREMENTS FOR EXTERNAL POWER SUPPLIES 

Introduction 
This  evaluation  is  of  Commission  Regulation  (EU)  2019/1782  laying  down  ecodesign 
requirements for external power supplies (EPS), hereafter referred to as ‘the EPS Regulation’. 
It was adopted as an implementing measure under the Ecodesign Directive (2009/125). The 
Ecodesign Directive and the EPS Regulation have the internal market provisions of the treaty 
as  their  legal  base  (now  TFEU  Article  114).  This  evaluation  was  carried  out  back-to-back 
with an impact assessment (IA) as part of the review required by Article 7 of the Commission 
Regulation. 

The  review  article  refers  to  the  need  to  carry  out  the  review  ‘in  the  light  of  technological 
progress’. In addition, the evaluation will primarily consider the effectiveness, efficiency and 
relevance  of  the  EPS  Regulation.  Because  the  regulation  is  adopted  under  the  Ecodesign 
Directive, it is not considered necessary to address the coherence and EU added value criteria 
in detail since they are presumed to have been assessed for the main Directive and therefore 
also apply to implementing measures adopted under it.  

The  methodology  used  for  the  evaluation  has  included  seeking  public  comments  on  the 
Commission Regulation, gathering manufacturer EPS data, review of literature and technical 
documentation and some limited testing of EPS. 

The period covered by the evaluation is from the date of adoption of the EPS Regulation in 
October 2019 to the present. The geographical scope of the evaluation is the whole EU.  

What was the expected outcome of the intervention?  
Description of the intervention and its objectives  

Under  the  Ecodesign  Directive  the  Commission  should  set  ecodesign  requirements  for 
energy-related products which account for significant volumes of sales and trade in the Union 
and  which  have  a  significant  environmental  impact  and  present  significant  potential  for 
improvement  through  design  in  terms  of  their  environmental  impact,  without  entailing 
excessive  costs.  Ecodesign  requirements  for  EPS  were  originally  established  in  Regulation 
(EC)  No  278/2009.  The  Commission  subsequently  reviewed  the  regulation  and  a  revised 
regulation45 was adopted after the normal procedure accompanied by an impact assessment46.  

The revised regulation was intended to set harmonised ecodesign requirements for the energy 
consumption  of  EPS.  These  requirements  were  intended  to  improve  the  environmental 
performance  of  EPS  and  contribute  to  the  functioning  of  the  internal  market.  The  main 
problems identified in the impact assessment were: outdated energy efficiency requirements; 
outdated  scope;  lack  of  readily  available  information  and  missed  opportunities  for 
contributing  to  circular  economy  objectives.  The  adopted  EPS  Regulation  addressed  the 
scope,  no-load  and  active  load  energy  efficiency  and  information  requirements.  It  did  not 
include any specific targeted circular economy requirements. It is considered that the impact 
assessment remains broadly relevant.  

45 Commission Regulation (EU) 2019/1782. 

46 SWD(2019) 345 of 1.10.2019. 

92 

 
 
 
At the time of adoption of the Commission Regulation it was considered to contribute to a set 
of  broader  policy  objectives.  The  main  ones  were:  the  Energy  Union  Framework  Strategy, 
which  called  for  a  sustainable,  low-carbon  and  climate-friendly  economy;  the  Paris 
Agreement, which called for a renewed effort in GHG emissions abatement; the Gothenburg 
Protocol,  which  aimed  at  controlling  air  pollution;  the  Circular  Economy  Initiative,  which 
amongst  others  stressed  the  need  to  include  reparability,  recyclability  and  durability  in 
ecodesign;  the  Emissions  Trading  Scheme  (ETS),  aimed  at  cost-effective  GHG  emissions 
reductions and was indirectly affected by energy consumption of ecodesign products; and the 
Energy Security Strategy, which set out a strategy to ensure a stable and abundant supply of 
energy. 

At the time of adoption there was no assessment of the UN Sustainable Development Goals 
(SDGs) that the EPS Regulation could contribute to. However, increased energy efficiency in 
line  with  other  ecodesign  regulations  is  expected  to  contribute  to  SDG  7  (affordable  and 
sustainable energy), SDG 8 (sustainable economic growth) and SDG 13 (climate action). The 
evaluation will provide evidence on the contribution this regulation makes to these SDGs. 

The general objectives of the intervention were described in the impact assessment to: 

1.  Facilitate free circulation of efficient EPSs in the internal market; 
2.  Create  or  expand  the  internal  market  for  more  sustainable  products  to  support 

competitiveness; 

3.  Promote  EPS  energy  efficiency  to  contribute  overall  EU  energy  and  climate 

objectives; 

4.  Contribute to reduced EU energy dependency and increased energy security. 

Figure 20 - Intervention Logic 

The  intervention  logic  shown  in  Figure  20  illustrates  how  the  needs  connect  with  the 
objectives  and  the  requirements  established  in  the  EPS  Regulation  to  deliver  the  expected 
achievements in terms of outputs, results and impacts. 

93 

 
 
 
 
The main achievements expected at the time of the impact assessment were:  

Changes in employment were expected as a consequence of the increased business turnover 
(shown  by  the  lower  saving  in  consumer  expenditure  compared  to  consumer  electricity 
savings).  

Closer alignment was expected with requirements in other economies (in particular the US) 
and  with  the  most  stringent  requirements  of  the  International  Efficiency  Marking  Protocol 
and finally there were expected to be limited impacts on SMEs manufacturing products that 
use EPS. 

These  outcomes  were  primarily  expected  to  be  delivered  by  the  stricter  energy  efficiency 
requirements  set  in  the EPS Regulation.  These would have a modest  cost  but  be more than 
offset  by  reduced  expenditure  due  to  the  energy  savings  throughout the life  of  the  product. 
The additional information was expected to support the choice of more efficient EPS and thus 
further boost energy savings.  

It was estimated that EPS manufacturers would bear compliance costs associated with testing. 
certification and documentation that of €5.29m, which equates to €0.01 per unit sale.  

Success  would  mean  that  only  products  meeting  the  minimum  requirements  set  in  the 
Regulation  would  be  placed  on  the  EU  market.  Compared  to  the  situation  without  the 
minimum requirements this would result in lower energy use and lower GHG emissions. 

As shown in Figure 20 several external factors may have affected the outcome, for example:  

•  Technological  progress  may  have  made  the  ecodesign  requirements  easier  and 

cheaper to comply with than anticipated; 

•  Since  the  same  EPS  are  likely  to  be  sold  in  multiple  jurisdictions  there  can  be  an 
impact  if  strict  requirements  are  set  in  those  jurisdictions  on  products  placed  on  the 
EU market;  

•  Changes in electricity supply costs can alter the level of consumer benefits achieved;  
•  The  GHG  intensity  of  EU  electricity  production  is  inversely  related  to  the  GHG 
benefit of using less electricity. If the intensity has reduced faster than expected then 
the GHG benefits of the Regulation will be lower. 

Points of comparison  

The key factors that will determine whether the expected energy savings are delivered will be 
the active energy efficiency requirements and the no-load power consumption limits. 

The  energy  savings  would  also  be  affected  if  use  patterns  had  changed  compared  to  those 
assumed, but no information is available on actual use patterns in the EU. 

The total level of energy savings will be affected by the annual sales of EPS and the overall 
stock of them.  

The level of GHG savings are a consequence of the level of electricity savings and the GHG 
intensity of electricity supply. 

94 

Impacts vs BAU202020252030Electricity savings (TWh)1.43.964.26GHG savings (Mt CO2eq/year)0.531.421.45Consumer electricity cost saving (€m/year)280810885Consumer expenditure saving (€m/year)169705787 
 
 
 
The level of primary energy savings will be affected by the electricity generation mix and the 
consequent primary energy factor. 

In view of these relationships, the relevant points of comparison would be: 

•  EPS sales and stock figures 
•  EPS active energy efficiency 
•  EPS no-load losses 
•  Electricity GHG intensity 
•  The electricity Primary Energy Factor 
•  Consumer electricity costs 

How has the situation evolved over the evaluation period? 
Current state of play  

As  the  intervention  was  in  the  form  of  a  regulation  no  implementation  was  required  by 
Member  States  and  therefore  also  no  infringements  have  occurred.  Member  States  do 
however have responsibility to carry out market surveillance and verify compliance with the 
requirements.  The  main  need  for  implementation  lies  with  business  which  needs  to  ensure 
that only EPS complying with the ecodesign requirements were procured and placed on the 
market  after  the  specified  dates.  No  difficulties  have  been  reported  in  complying  with  the 
legal requirements by any of the actors involved. 

A complication with EPS is that the vast majority are not sold separately but are bundled with 
other  products  that  they  are  intended  to  be  used  to  power.  There  is  therefore  no  readily 
available  information  from  the  market  on  either  the  quantities  of  EPS  sold  or  their  cost  or 
price. This situation is broadly the same as at the time of the previous impact assessment. 

Estimates of the impact of the regulation are made annually as part of the Ecodesign Impact 
Accounting. However, these estimates essentially take the product related assumptions in the 
previous impact assessment  and update them with any  changes in  relevant  external  factors. 
They do not constitute actual monitoring of the market. 

Evolution of relevant parameters 

Energy efficiency 

It  was  assumed  that  in  the  absence  of  any  regulation,  active  mode  losses  would  decrease 
autonomously  by  1%  per  year  due  to  technical  developments.  In  view  of  this,  the  active 
efficiency would have improved as shown in Figure 21 below. It is clear from this figure that 
even in the best case the active efficiency would not have reached the same level as in the US 
by 2030.  

EU Regulation 278/2009 

2019 

2020 

2025 

2030  US DoE 

 Lower efficiency 
 Upper efficiency 

65.5%  65.8%  67.5%  67.8%  70.9% 
87.0%  87.1%  87.8%  87.9%  88.0% 

Figure 21 - Illustrative autonomous active efficiency improvement 

If it was assumed that no-load efficiency would have improved autonomously by 1% per year 
the no-load losses would have decreased as shown in Figure 22 below. At this rate, by 2030 
the  autonomous  improvement  would  only  have  reduced  the  no-load  losses  by  1/7  of  that 
achievable by alignment with the US DoE requirements. 

95 

 
 
 
Lower no-load losses (W) 

Upper no-load losses (W) 

2019 

0.3 

0.5 

2020 

0.297 

0.495 

2025 

0.282 

0.471 

2030 

0.269 

0.448 

US DoE 

0.1 

0.3 

Figure 22 Projected autonomous improvement in no-load losses 

Sales 

The  assumed  EU-28  EPS  sales  from  the  IA  are  shown  in  Figure  23.  Sales  figures  were 
assumed  to  not  change  from  the  BAU  sales  after  introduction  of  the  requirements  in  the 
regulation since the EPS are primarily supplied with a product and demand for those would 
be unaffected by the intervention. 

Figure 23  - (from the 2019 IA) – Assumed annual EPS sales 
No  additional  detailed  information  is  available  on  how  sales  have  evolved.  A  key  factor 
affecting  the  number  of  sales  in  the  EU  is  the  effect  of  the  UK  leaving  the  EU.  UK  sales 
accounted  for  about  a  15%  share  of  sales  and  so  after  adjustment  they  follow  the  pattern 
shown in Figure 24: 

Sales prices 

Figure 24 Expected EPS sales from Ecodesign Impact Accounting 2021 

Because EPS are primarily sold bundled with other products there is no  market information 
available on selling prices. The analysis in the impact assessment was based on assumptions 

96 

SALESECO, 000 units 20102015202020252030EPS  ≤ 6W, low-V6470945970313902262811840EPS 6–10 W185600200639214358224632236049EPS 10–12 W102872122894132503133725134558EPS 15–20 W6483911753083549317EPS 20–30 W1254913003120271151610838EPS 30–65 W, multiple-V00131319472709EPS 30-65 W00105425994470EPS 65–120 W455844423393188845EPS 65–120 W, multiple-V203307374217421942208EPS 12–15 W967219621239112413224282EPS, total400937417854429653433615436316 
 
 
  
 
 
about  the  volume  of  product  sales  and  their  notional  prices.  No  information  is  available  to 
check these assumptions. 

Other relevant changes 
A  relevant  evolution  is  the  adoption  of  the  revised  Radio  Equipment  Directive47  among 
others  for  mobile  phones,  tablets  and  laptops.  This  aims  at  the  proliferation  and  reuse  of  a 
‘universal’ USB-PD charger. It requires devices in its scope to be powered through a USB-C 
connector with a USB protocol. Devices in its scope are currently powered by around 50% of 
all EPS in the current scope of the Regulation. 
It is also relevant to note that authorities in the United States48 and in Australia49 have started 
reviews of their legislation regulating EPS. 

Sources of evidence 

A call for evidence was launched50 to gather inputs for the evaluation and impact assessment. 
Most  of  the  inputs  received  were  opinions  about  future  development  of  the  policy  and 
therefore not relevant for the evaluation. Further details of the limited comments relevant to 
the evaluation are provided in Annex V. 

There  is  no  specific  reporting  requirement  in  the  regulation.  However,  the  Market 
Surveillance Authorities (MSAs) provide information in the ICSMS database on the results of 
market  surveillance  activities.  Only  Germany  has  provided  this  information  for  EPS  in  the 
database, and Denmark provided market surveillance information separately. 

An  evaluation  questionnaire  was  sent  to  the  members  of  the  Consultation  Forum  in  2022. 
Only  two  responses  were  received  to  this  questionnaire  (from  Germany  and  Switzerland). 
providing mainly market surveillance information for 2021. 

The following additional sources of information were used: 

• 
• 

• 

• 

EPS energy efficiency information from online manufacturer catalogues 
Generic market information from an interview with a component manufacturer 
(Power Integrations) 
Non-destructive  testing  of  a  number  of  EPS  at  different  energy  consumption 
levels 
Ecodesign Impact Accounting (EIA) report 2021 

A database with EPS data on no-load energy consumption, active efficiency and efficiency at 
10% load, was populated with around 500 entries sourced from manufacturers’ public online 
information.   While this data has not been independently verified, it ought to provide a good 
illustration of the performance of EPS on the market, given that an EPS is a product easy to 
test, without user settings and corresponding variations in “real-world” performance. 

Limitations 

47  Directive  (EU)  2022/2380  of  23  November 2022  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. 
48 https://www1.eere.energy.gov/buildings/appliance_standards/standards.aspx?productid=1 . 
49 Interview and email exchanges with the contractors of the Australian government.  

50https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13351-External-power-supplies-
ecodesign-information-requirements-review-_en 

97 

 
 
 
As  noted,  there  are  significant  weaknesses  in  the  information  available  to  assess  certain 
aspects of the intervention. The lack of sales data means that it is not possible to see whether 
there  has  been  any  change  in  the  number  of  EPS  sold  or  in  which  categories.  No  data  is 
available on use patterns of EPS to verify the assumptions used previously. The absence of 
pricing information, primarily due to the bundling of EPS with the products they are used to 
power has prevented any assessment of the impact of the Regulation sale prices. No sources 
of cost information have been identified other than ongoing US work on a future revision of 
US  regulations and bilateral  industry contacts  for confirmation  of the likely  impacts.  These 
factors limit the ability to assess the cost-efficiency of the EPS Regulation. 

Evaluation findings 
Question 4.1 – To what extent was the intervention successful and why?  

The  answer  to  this  evaluation  question  is  based  upon  the  assessment  of  the  three  criteria 
effectiveness,  efficiency,  coherence.  Coherence  is  implicitly  assumed  as  the  intervention 
being evaluated is an Implementing Measure. 

The evidence gathered shows that to a large degree products are compliant with the no-load 
and  active  load  energy  efficiency  requirements  and  the  information  requirements  including 
efficiency at 10% load. As a result of over-compliance, partly offset by the reduced size of 
the  EU,  actual  electricity  savings  are  calculated  to  be  around  13%  higher  than  projected  in 
2025. 

With regard to the progress on energy efficiency, some part of this could have been expected 
to  have  happened  without  the  Regulation  due  to  business-as-usual  evolution  and  product 
replacement,  autonomous  technical  progress  including  new  semiconductor  types  and  spill 
over impacts of regulations in other jurisdictions (in particular the USA). 

It is unlikely that information at 10% load would have been provided without the regulation’s 
requirement  since  this  was  largely  absent  earlier.  Similarly,  the  specific  information 
requirements on the EPS could not have been expected to be universally applied if they were 
not in the regulation. 

Actual primary energy savings are lower than projected in the IA since the electricity Primary 
Energy Factor has progressively reduced due to changes in the electricity generation mix. The 
primary energy savings in 2025 are calculated to be around 15% lower than projected for this 
reason (see annex IV). 

Actual  GHG  savings  are  lower  than  projected  in  the  IA  since  decarbonisation  of  the 
electricity mix has happened more rapidly than was projected. The GHG intensity was around 
39%  lower  than  assumed  in  2020  but  this  discrepancy  reduced  to  26%  in  2021  due  to  the 
temporary rebound in coal fired generation in that year. The intensity is projected to be 50% 
lower by 2025. GHG savings are therefore likely to  be in  the range of 15 to  45% lower as 
shown in annex IV. 

Unfortunately,  there  is  limited  market  surveillance  information  available.  What  is  available 
points  to  a  certain  non-compliant  share  of  products  tested.  This  is  supported  by  the 
independent  testing  carried  out  in  support  of  this  evaluation  and  by  the  manufacturer  data. 
While the manufacturer data shows a low share of EPS with reported parameters not in line 
with  the  regulation  requirements,  there  may  be  other  reasons  for  non-compliance  such  as 
failure  to  provide  appropriate  information.  Unfortunately,  it  is  not  possible  to  draw  any 
conclusions on the overall share of non-compliant products since market surveillance actions 
tend to be focussed on products that are considered to be of higher risk. 

98 

 
 
With regard to the efficiency of the regulation, it has unfortunately been impossible to gather 
any direct information on the cost to manufacturers of implementing the requirements or any 
change in product price. Similarly, it has not been possible to gather any information on the 
testing and administrative costs. No respondents provided any information in the consultation 
or  has  provided  any  information  directly.  In  view  of  this  lack  of  information  it  is  assumed 
that the administrative and adjustment costs have not been higher than projected in the impact 
assessment. 

Efficiency can however be inferred from the fact that none of the industry stakeholders has 
raised  the  cost  of  compliance  with  the  requirements  as  an  issue  during  the  evaluation. 
Similarly, the scale of costs that have been identified in the work carried out for the US DoE 
for further stringency requirements illustrate that the underlying cost assumptions used in the 
IA were of the right order of magnitude.  

As  identified  in  the  impact  assessment,  there  can  be  significant  cost  efficiencies  through 
compatible levels  of energy efficiency requirements  applying to EPS sold globally.  If these 
did materialise they would have been expected to lead to lower consumer costs. There have 
not  been  changes  in  other  major  jurisdictions  in  the  intervening  period,  but  reviews  are 
underway in at least Australia and the United States. 

In  view  of  this  evidence,  it  can  be  concluded  that  the  intervention  has  contributed  to 
achieving the outcomes it aimed at. Some part of the energy efficiency progress might have 
occurred anyway, but nonetheless there is clearly benefit from the intervention. The lack of 
evidence  on  costs  and  the  indirect  evidence  suggest  that  costs  were  not  higher  than 
anticipated in the impact assessment. In view of these factors the intervention can be judged 
to have been a success, achieving more electricity savings than expected albeit delivering less 
GHG and primary energy benefits due to external factors. 

More  detailed  analysis  by  criterion  is  documented  in  Annex  III  (answers  to  the  evaluation 
questions).  

Question 4.2 - How did the EU intervention make a difference and to whom?  

There is  currently no known intervention  at  Member State level  specifically targeting EPS. 
By virtue of an EU-wide measure, suppliers have the same set of (harmonised) requirements 
across the whole EU Single Market. This removes the risk of having to perform different tests 
and  other  performance  assessments  and  having  to  meet  different  national  requirements  as 
regards labelling when placing products on national markets.  

For consumers and component integrators, the intervention brings added value as it provides 
information on characteristics for choosing an EPS. For EPS producers and wholesalers the 
added  value  is  that  they  can  use  the  same  models  for  the  entire  EU  market  and  are  not 
required to prepare for different requirements at national level. 

For market surveillance the added value of the EU measure lies in the mutual recognition of 
verification  assessments  performed  in  other  countries.  National  authorities  do  not  need  to 
perform verification tests on products already verified by other authorities. 

If the EU  ecodesign  requirements were stopped  it could  prompt ‘dumping’ of less efficient 
EPS on the EU market as was feared because of stricter US legislation before the regulation 
was adopted. These less efficient EPS would lead to higher electricity losses and thus higher 
consumer  costs  as  well  as  an  increase  in  GHG  and  pollutant  emissions  and  material 
consumption  from  electricity  generation.  These  factors  might  prompt  Member  States  to 
develop requirements themselves. This would affect the functioning of the EU Single Market 
and would be expected to lead to higher product costs due to the multiplicity of requirements. 

99 

 
 
The impacts of the EU intervention have been primarily felt by consumers who have received 
the  benefits  of  the  higher  energy  efficiency  of  EPS  on  the  EU  market  and  thus  lower 
electricity  consumption  and  cost  savings.  It  is  not  expected  that  there  would  have  been 
substantial  impacts  on  business  producing  or  selling  EPS  since  there  isn’t  evidence  of 
significant product price changes that would have led to a difference in sales or revenues. 

Question 4.3 - Is the intervention still relevant?  

The objectives of the intervention relating to the single market, promoting energy efficiency 
and  contributing  to  EU  energy  and  climate  goals.  have  remained  relevant  over  the 
implementation period. The EU is celebrating the 30th anniversary of the single market51 and 
regards the role it plays as important as ever. The EPS Regulation continues to be relevant to 
contribute to the single market. 

Climate and energy policies are a key element of the European Green Deal and further action 
to increase energy efficiency and reduce GHG emissions have been agreed. The Regulation 
remains relevant to contribute to these. While its contribution to the overall energy security 
objective  is  small,  the  Russian  aggression  in  Ukraine  has  reinforced  attention  on  energy 
security and therefore this contribution also remains relevant. 

The range of types of products requiring EPS on the market not within the scope of regulation 
has grown (e.g. products with charging as a secondary function, wireless chargers, e-bikes). 
In  view  of  this  the  regulation  now  addresses  to  a  certain  extent  a  smaller  share  of  relevant 
products than it did at the time of adoption.  

Since adoption of the regulation there has been an increased focus on the Circular Economy. 
While  the  regulation  results  in  substantial  material  savings  through  reduced  electricity 
consumption,  it  does  not  contain  any  specific  measure  targeting  product  lifetime  or  end  of 
life.  At  the  end  of  their  active  use  EPS  become  part  of  e-waste52.  The  Circular  Economy 
Action Plan calls for measures to reduce e-waste with goals like creating the right to repair 
and  improving  reusability  in  general,  introduction  of  a  common  charger  and  establishing  a 
rewards system to encourage recycling electronics. Since most EPS have a longer technical 
life  than  the  products  they  power,  they  may  accumulate  in  households  for  years  and  then 
become e-waste.  

Products requiring an EPS continue to be purchased and their range is expanding while the 
policy objectives also remain relevant and are also being strengthened. Taken together these 
show that the intervention remains relevant. The available market evidence appears to show 
good overall compliance with the requirements, however, the limited information on market 
surveillance makes it difficult to be certain how effective the intervention is in contributing to 
its objectives. 

New semiconductor technologies offer higher efficiency and smaller geometry, which are in 
turn  opportunities  for  further  improvements.  The  introduction  of  the  USB-PD  protocol  has 
made  interoperability  of  EPS  feasible,  but  this  does  not  appear  to  have  yet  led  to  any 
significant reuse of EPS and reduction of bundled sales. 

51 https://single-market-economy.ec.europa.eu/single-market/30th-anniversary_en. 

52 About half a billion chargers for portable devices shipped into Europe each year, generate 11000 to 13000 
tonnes out of total 4.7 million tons of waste electrical and electronic equipment collected in the EU in year 2020.   
https://www.europarl.europa.eu/news/en/press-room/20220429IPR28224/common-charger-parliament-
commits-to-reducing-electronic-waste. 

100 

 
 
 
The  regulation  set  EPS  efficiency  requirements  at  level  VI  on  the  globally  agreed  energy 
efficiency  scale.  It  was  adopted  following  comparable  legislation  in  the  US  and  Canada. 
While this level has become de-facto  a global standard, other jurisdictions, like the US and 
Australia,  are  now  reviewing  their  requirements.  A  strengthening  of  requirements  in  other 
jurisdictions will support the case for reviewing the stringency of EU requirements.  

Consumers  are  probably  unaware  of  the  energy  efficiency  of  EPS  and  are  unlikely  to  give 
much  consideration  to  it  when  making  a  purchase,  especially  since  most  EPS  are  sold 
bundled  with  products.  Despite  this,  given  the  lengthy  periods  for  which  most  EPS  will  be 
used, the potential energy and cost savings for consumers are non-negligible. Technological 
development  suggests  that  there  could  be  further  savings  to  be  realised  in  the  future  that 
would be unlikely to materialise in the absence of regulatory requirements.   

Consumers’  need  for  information  on  the  characteristics  and  performance  of  EPS  remains 
valid. Even with adaptive EPS it is still important to have EPS with adequate power for the 
powered device. As more devices and EPS are powered via interchangeable connectors such 
as  USB-C,  the  need  for  information  increases  as  the  same  EPS  can  be  used  with  multiple 
products. This need is likely to increase as more devices can be interchanged with different 
EPS and the number of different products requiring an EPS grows.  

In  view  of  these  considerations,  the  regulation  remains  relevant  for  providing  relevant 
information  to  consumers  to  choose  a  proper  EPS  and  for  providing  them  with  energy  and 
costs savings that they would otherwise forego. 

What are the conclusions and the lessons learned?  
The conclusions presented in this section result from the evidence that has been gathered and 
the analysis carried out. 

Did the intervention achieve its objectives?  

While there is limited market surveillance information, the evidence suggests that to a large 
part  EPS  placed  on  the  EU  market  mainly  comply  with  the  active  and  no-load  efficiency 
requirements. Information requirements appear to be respected and information on 10% load 
efficiency has been provided. 

No unintended consequences of the intervention have been identified. It has not been possible 
to gather explicit evidence of whether the intervention was more or less costly than expected, 
however indirect evidence suggests that it was not more costly. 

Some  part  of  the  anticipated  energy  savings  is  likely  to  have  resulted  from  autonomous 
technical  progress  and  spill  over  effects  from  regulation  in  other  parts  of  the  world.  Offset 
against  that  was  the  risk  identified  in  the  impact  assessment  of  ‘dumping’  of  EPS  not 
compliant with requirements in the other jurisdictions in the EU. This has not happened. 

While it would have been possible for Member States to have set equivalent requirements at 
national level, it is unlikely that these would have been uniform and the cost of establishing 
them  and  testing  compliance  for  them  and  overseeing  them  would  have  been  higher  than 
setting a single set of requirements at EU level for the single market. 

It can be concluded that the Regulation has broadly achieved its objectives. 

Did  the  EU  bring  actors  together  to  work  on  shared  solutions  that  would  not  have 
happened otherwise?  

The alignment of the EU energy efficiency requirements for EPS with the international level 
VI requirements will have led to economies of scale globally as manufacturers will have been 

101 

 
 
able  to  develop  and  market  single  EPS  compliance  with  the  requirements  in  the  major 
jurisdictions. This is assumed to have ultimately led to lower consumer prices. 

The fact that authorities in the USA and Australia are currently reviewing their requirements 
may  support  the  need  for  a  review  of  EU  requirements  to  ensure  the  benefits  of  continued 
alignment. 

What  are  the  lessons  that  can  be  derived  from  this  primarily  backward-looking 
exercise? 

The  underlying  rationale  for  the  intervention  remains,  in  that  there  will  be  market  failures 
meaning  that EPS energy efficiency  will not  arrive at  cost-optimal levels from  the point of 
society from market forces alone. 

Market  data  shows  a  considerable  spread  of  energy  efficiency  performance.  Technology 
continues to evolve, in particular with new types of semiconductors, and this means that are 
likely to be opportunities for more stringent requirements in the future. 

The range of products powered by EPS continues to grow. This suggests that there may be a 
growing  number  of  products  outside  the  current  scope.  This  implies  that  there  could  be 
benefit from a review of the scope of the regulation.  

The above factors point to the continuation of problems that justified the intervention. 

In addition, there are a number of evolutions that suggest other potential benefits in reviewing 
the requirements.  

Information has been gathered on energy efficiency at low-load. This shows lower efficiency 
than at higher load levels, as was assumed, and appears to indicate a range of performance at 
this load level. These factors might merit specific action. 

The regulation did not include any elements specifically related to the circular economy. In 
view of the increased focus in this policy area, it may be worth exploring whether there are 
aspects of the EPS market that could be addressed from a circular economy perspective and 
lead to benefits for consumers and the environment. 

Since  the  regulations  are  single  market  measures,  they  are  assumed  to  represent  a 
simplification  compared  to  the  situation  without  them.  The  provisions  for  compliance  are 
standard  and  there  are  no  obvious  routes  to  reduce  their  burden.  Market  surveillance 
weaknesses risk undermining compliance and thus allowing for free-riders while reducing the 
energy saving benefits. 

No issues have been raised or identified in relation to complexity or excessive cost and it is 
concluded  that  there  are  no  obvious  inefficiencies  or  opportunities  for  simplification  or 
burden reduction. 

No  problems  of  internal  coherence  have  been  identified  or  other  coherence  with  other  EU 
legislation. No changes have been identified in the targeted businesses that  would suggest a 
need for a different policy design in future. 

102 

 
 
 
Evaluation Annex I. Methodology used  

Figure  25  -  Overview  of  the  evaluation  methodologybelow  shows  the  overall  methodology 
used for the evaluation as well as the main steps followed and the types of data sources used 
during the process. 

Figure 25 - Overview of the evaluation methodology 

103 

 
 
 
Evaluation Annex II. Evaluation matrix and answers to the evaluation questions (by criterion)  

Effectiveness 

Data sources 

Success  criteria 
comparison) 

(points  of 

Indicator(s) 
quantitative  or 
qualitative 

1. What progress has been made over time towards achieving the objectives and target? 

Q 1.1 Has the no load energy consumption of EPS sold 
in the EU improved?  

What  would  have  been  the  improvement  in  the  BaU 
situation  and  also  developments  have  been  seen  in 
other parts of the world? 

Q  1.2  Has  the  average  active  efficiency  of  EPS  sold  in 
the EU as a whole improved?  

What  would  have  been  the  improvement  in  the  BaU 
situation  and  what  developments  have  been  seen  in 
other parts of the world? 

Q. 1.3  To what extent  can the achieved improvements 
be attributed to the EPS ecodesign requirements? 

Manufacturer data 

No load power consumption 

Quantitative  

Interviews 

Testing unbundled EPS 

Market surveillance 

Impact Assessment 

Manufacturer data 

Interviews 

Testing unbundled EPS 

Market surveillance 

Impact Assessment 

Consultation 

Interviews 

Analysis 

104 

load  power  energy 

Active 
efficiency 

Quantitative  

Alternative  explanations 
progress 

for 

Qualitative  

 
 
 
Q.  1.4  Has  the  required  energy  efficiency  information 
been made available to consumers? How? 

Market data  

Observation 

Information available on EPS 

Qualitative  

2. How successful has the regulation been in achieving or progressing towards its objectives? 

Q. 2.1 Do the electricity savings match the expectations 
from the Impact Assessment? 

Manufacturer data 

Electricity savings 

Quantitative 

Ecodesign Impact Accounting 

Impact Assessment 

Q. 2.2 Do the GHG savings match the expectations from 
the Impact Assessment? 

Calculated electricity savings 

GHG savings 

Outturn electricity GHG intensity 

Q.  2.3  Do  the  primary  energy  savings  match  the 
expectations from the Impact Assessment? 

Calculated electricity savings 

Primary energy savings 

Revised PEF values 

Q. 2.4 Do the consumer energy cost savings match the 
expectations from the Impact Assessment? 

Q.  2.5  Are  their  unexpected  outcomes  from  the 
Regulation? 

Calculated electricity savings 

Consumer energy cost savings 

Outturn electricity prices 

Market observations 

Manufacturer data 

3. What factors have contributed to or hindered their achievement? 

3.1  To  what  extent  have  the  ecodesign  requirements 
been  sufficient 
improving  EPS 
performance  and  meet  minimum  energy  efficiency 
requirements?  

to  contribute 

to 

Alternative  explanations 
progress 

for 

Qualitative 

Consultation 

Interviews 

Literature 

Questions to Commission 

105 

 
 
 
 
 
 
 
3.2  Have  there  been  EPS  technological  improvements 
that contributed to increased energy efficiency? 

3.3  What  external  factors  have  affected  progress 
towards the objectives, and how are they linked to the 
EU intervention? 

Consultation 

Interviews 

Literature 

Consultation 

Interviews 

Literature 

Technological progress 

Qualitative 

Identified external factors 

Qualitative  

4. How effective has the implementation and enforcement of the Regulation? 

4.1 Status of market surveillance in MS?  

ICSMS database MS information 

Rates of surveillance 

Quantitative 

Does it differ compared to other products regulated by 
the Ecodesign Directive? 

Is  there  non-compliance  with  the  Regulation 

4.2 
requirements? 

If so, how much of that is due to poor enforcement? 

Market surveillance 

Testing unbundled EPS 

Manufacturer data 

of 

Rate 
compliance 

identified 

non-

Quantitative and 
Qualitative 

Efficiency 

Data sources 

Success criteria (points of 
comparison) 

Indicator(s) quantitative 
or qualitative 

Q4.  Are 
proportionate to the benefits? 

the  costs 

related 

to 

the  Regulation 

Consultation 

Administrative costs 

Qualitative 

Price information 

106 

 
 
 
 
 
Relevance 

Data sources 

Success criteria (points of 
comparison) 

Indicator(s) quantitative 
or qualitative 

Q5. Does the Regulation correspond to the current needs of the EU? 

Q  5.1  How  did  the  objectives  of  the  intervention 
correspond to wider EU policy goals and priorities? 

Q 5.2 To what extent is the intervention still relevant in 
view of its objectives?  

How well do the (original) objectives of the intervention 
still correspond to the needs of the EU? 

Q 5.3 To what extent do the needs/problems addressed 
by  the  intervention  continue  to  require  action  at  EU 
level? 

Q  5.4  How  well  adapted  is  the  intervention  to  the 
technological  progress  that  has  happened  since  its 
introduction? 

How  well  adapted  is  the  intervention  to  social  and 
environmental changes? 

EU policy documents Literature 

Priority EU goals 

Qualitative 

EU policy documents 

Relevance of objectives  

Qualitative 

Literature 

EU policy documents 

Continuation of needs 

Qualitative 

Literature 

Consultation 

New needs 

Qualitative 

Interviews 

Literature 

Q.  5.5  Are  the  regulation’s  requirements  sufficiently 
stringent 
in  other 
in 
jurisdictions? 

view  of  developments 

Information 
jurisdictions 

on 

other 

Stringency 
jurisdictions 

in 

other 

Quantitative 

Q 5.6 How relevant is the intervention to EU citizens?  

Consultation 

Consumer needs 

Qualitative 

Will  it  continue  to  be  relevant  for  them  in  the  near 
future? 

Literature 

107 

 
 
 
Q6. How flexible is the Regulation with regard to other 
policies and new issues? 

Analysis 

Need for flexibility 

Qualitative 

Coherence 

Coherence  is  not  investigated  in  detail  in  this  evaluation  because  the  intervention  is  an  implementing  measure  adopted  under  a  framework 
Directive. It is assumed that provided the Directive and its requirements is coherent with other policy objectives and goals then the implementing 
measures will also be coherent. This evaluation does not assess the coherence of the Ecodesign Directive, however the impact assessment and 
ESPR legislative proposal to amend that legal framework recognised that the framework is coherent with EU policy goals and objectives and 
proposes to extend that framework to a wider range of products while bringing in additional possibilities for action. The following coherence 
questions are considered: 

Coherence 

Data sources 

Success  criteria 
comparison) 

(points  of 

Indicator(s)  quantitative  or 
qualitative 

Q7 How coherent is the EU intervention? 

Q 7.1. To what extent is the intervention coherent 
internally,  with  other  interventions  with  similar 
objectives and with wider EU policy? 

policy 

EU 
Literature 

documents 

Ecodesign  regulations  and  EU 
policy documents  

Qualitative 

Q  7.2  To  what  extent  is  the  intervention  coherent 
with international obligations? 

EU policy documents 

Literature 

Qualitative 

EU added value 

EU added value is not investigated in detail in this evaluation because the intervention is an implementing measure adopted under a framework 
Directive. It is assumed that provided the Directive and its requirements provide EU added value then the implementing measures will also. 

The  Framework  Directive  has  the  internal  market  provision  of  the  Treaty  as  its  legal  base.  The  implementing  measures  adopted  under  the 
framework will bring harmonised product requirements across the EU Single Market. This results in single test and performance assessments for 
the  single  market  thus  minimising  costs.  In  market  surveillance  there  is  added  value  from  the  mutual  recognition  of  verification  assessments 
performed in other Member States.  

108 

 
 
 
EU added value 

Data sources 

Success  criteria  (points 
of comparison) 

Indicator(s) quantitative 
or qualitative 

Q8. What is the EU added value of the intervention? 

Q.  8.1  What  is  the  additional  value  resulting  from  the  EU 
intervention.  compared  to  what  could  reasonably  have  been 
expected  from  Member  States  acting  at  national  and/or  regional 
levels? 

EU  policy  documents 
Literature 

Contribution 
single market 

to 

the 

Qualitative 

Q. 8.2 What would be the most likely consequences of stopping or 
withdrawing the existing EU intervention? 

EU  policy  documents 
Literature 

Contribution 
single market 

to 

the 

Qualitative 

109 

 
 
Evaluation Annex III. Answers to the evaluation questions 

Effectiveness 

1. What progress has been made over time towards achieving the objectives and target? 

Q 1.1 Has the no load energy consumption of EPS sold in the EU improved?  

What would have been the improvement in the BaU situation and with developments in other 
parts of the world?  

EPS regulatory 
requirements  

No-load  power 
consumption  

Equivalent  to  International 
Efficiency Marking Protocol 

US DoE 

0.10 - 0.30 W 

Level VI 

EU Regulation 278/2009 

0.30 - 0.50 W 

Level V 

Figure 26 shows the situation before the Regulation was put in place and the EU ecodesign 
no-load power requirements were less stringent than the US DoE requirements. 

EPS regulatory 
requirements  

No-load  power 
consumption  

Equivalent  to  International 
Efficiency Marking Protocol 

US DoE 

0.10 - 0.30 W 

Level VI 

EU Regulation 278/2009 

0.30 - 0.50 W 

Level V 

Figure 26 - Comparison of EU and US requirements shown in 2019 IA 

The  impact  assessment  reported  no-load  power  consumption  of  EPS  of  0.3  to  0.5W.  It  was 
expected  that  these  would  reduce  through  technical  progress  by  around  1%  per  year.  This 
would imply a 5% reduction since 2018 to around 0.28 and 0.47W by 2025. 

The  main  source  of  information  on  the  impact  on  no-load  power  consumption  is  the  EPS 
database of manufacturer information. Manufacturer no-load power consumption information 
in  Figure  27  show  that,  for  most  EPS,  manufacturers  report  no-load  losses  less  than  the 
regulated limits. 

Figure 27 - EPS no load power consumption as reported by manufacturers 

For  AC-DC  EPS  except  low  voltage,  manufacturer  data  shows  2.4%  (9  out  of  369)  of  the 
sample with no-load consumption above the regulated level. For low voltage EPS 1.8% (1 out 
of 57) report no-load consumption above the regulated level. 

110 

 
 
 
 
Figure 28 - No-load energy consumption of the tested EPS 

Some  limited  testing  of  EPS  performance  has  also  been  carried  out  during  the  evaluation. 
Figure 28 shows the no-load results from this. The small number of fixed voltage EPS shown 
by the grey rings appear to show a similar pattern to that in the manufacturer data.  

Most  of  the  testing  was  on  USB-PD  EPSs  (green,  red.  and  yellow  circles).  This  appears  to 
show no-load consumption in the same range as for fixed voltage EPSs (grey rings). It can be 
seen that some EPS are not in line with the two no-load consumption thresholds. Although not 
explicitly  shown  on  this  graph,  EPSs  using  silicon  and  gallium  nitride  have  similar  no-load 
consumption. 

Figure 29 - No-load energy consumption at different voltage outputs 

An  ‘adaptive  no-load’  condition  is  assumed  where  the  EPS  is  connected  to  the  load,  not 
drawing  power,  but  only  to  pre-set  the  output  voltage  (9V-48V).  Figure  29  shows  that  for 
adaptive EPS in these cases the no-load power is much higher than the default 5V no load and 
increases  with  output  voltage.  The  uncertainty  of  the  interpretation  and  the  observed 
variations in performance indicate a need for clarification of the requirements. 

111 

 
 
 
 
Overall,  these  data  show  that  EPS  no-load  consumption  appears  to  be  in  line  with  the 
regulated  requirements.  This  would  not  have  been  expected  to  occur  through  autonomous 
market developments.  

As  the  US  DoE  also  regulates  EPS  for  no-load  conditions,  and  in  most  cases,  EPS  are 
produced to supply globally, it is probable that some improvement in EU EPS no-load power 
would have been observed as a result of spill over from that no-load consumption threshold. 

Q 1.2 Has the average active efficiency of EPS sold in the EU as a whole improved?  

What  would  have  been  the  improvement  in  the  BaU  situation  and  what  developments  have 
been seen in other parts of the world?  

Figure 30 shows the situation before the Regulation was put in place and the EU ecodesign 
active efficiency requirements were less stringent than the US DoE requirements. 

EPS regulatory 
requirements  

Average 
efficiency 

active 

Equivalent 
Efficiency Marking Protocol 

International 

to 

US DoE 

0.709 – 0.880 

Level VI 

EU Regulation 278/2009 

0.655 – 0.870 

Level V 

Figure 30 - Comparison of EU and US requirements shown in 2019 IA 

The  active  efficiency  for  EPS  in  scope  was  assumed  to  improve  autonomously  but  very 
slowly beyond the existing minimum requirements. There was also considered to be a risk of 
EPS banned in  the US  entering  the EU market  since they could  not  be sold  anymore in  the 
US. 

An illustration of the how the efficiency distribution was expected to evolve under BaU for 
one type of EPS without the intervention is shown in Figure 31 below (figure 12 of the IA). 

Figure 31 - Distribution of EPS efficiency for one type of EPS 

Single voltage EPS except low voltage 

Figure  32  shows  information  published  by  manufacturers  of  the  active  average  energy 
efficiency of single voltage EPS other than low voltage. This shows the majority of published 
data  on  EPS  are  in  line  with  the  requirements  of  the  Regulation.  Only  2.4%  (9  out  of  369) 
report  efficiency  below  the  regulated  limit.  The  EPS  with  average  efficiency  above  the 
requirements of the Regulation show a spread up to 5% points above the requirements.  

112 

 
 
 
Figure 32 - EPS average active efficiency reported by manufacturers 

Very similar performance and spread is reported in the United States as shown in Figure 33. 
These two analyses show that active-mode efficiency for basic voltage EPSs follow a similar 
efficiency level pattern globally as EPS are produced for the global market.  

Figure 33 - EPS active mode performance (US DoE) 53 

Low voltage EPS 

Figure  34  shows  that  manufacturers’  catalogues  predominantly  show  active  average 
efficiency  performance  levels  compliant  to  the  regulated  requirements  for  EPS  with  low 
voltage outputs.  

53  Source:  U.S.  DOE.  2022.  Technical  Support  Document  (TSD):  Energy  Efficiency  Program  for  Consumer 
Products  and  Commercial  and 
from: 
https://www.regulations.gov/document/EERE-2020-BT-STD-0006-0012. 

Industrial  Equipment:  External  Power  Supplies.  Retrieved 

113 

 
 
 
 
 
Figure 34 - Average active efficiency of low voltage EPS reported by manufacturers 

Adaptive EPS 

To  estimate  the  real-life  active  mode  efficiency  and  its  variation  with  output  voltage,  the 
average 4-point efficiency was measured for USB-PD EPS54. The results are shown in Figure 
35 and Figure 36. In most cases, the highest efficiency is obtained at maximum voltage, but in 
some cases the highest efficiency is at an intermediate voltage. 

Figure 35 - Efficiency of USB-PD EPSs vs output voltage 

Note: Red are the cheapest EPS. Yellow by low-end OEMs. light green by large OEMs. and 
dark green by the end-device manufacturer (though often manufactured by an OEM) 

54  Note  that  the  measurements  did  not  consider  the  effect  of  the  cable  which  is  required  by  the  measurement 
standard, so the efficiency results are to a certain extent overestimated.  

114 

 
 
 
 
 
Figure 36 - Efficiency of USB-PD EPSs vs output voltage 

Active efficiency at 10% load 

The  previous  Regulation  contained  no  ecodesign  requirements  for  multiple  voltage  output 
EPS, no information requirement for EPS efficiency at 10% load and no general information 
requirement on EPS performance. In the absence of any requirements there was not expected 
to  be  any  change  in  the  provision  of  this  information  or  efficiency  of  multi  voltage  output 
EPS. 

In  terms  of  evolution,  the  problem  of  EPS  providing  power  output  at  around  10%  of  their 
maximum was expected to increase due to more appliances being  always on and in standby 
mode at lower power levels, including networked devices. Similarly, multiple voltage output 
EPS  were  expected  to  become  increasingly  popular  and  provide  a  means  of  circumventing 
requirements that only apply to single voltage output EPS. 

The  regulation  requires  the  reporting  of  average  efficiency  at  10%  load.  Figure  37  shows 
manufacturer reported data on efficiency at 10% load on the left for EPS except low voltage 
and on the right low voltage. 

Figure 37 Graphs showing manufacturer reported efficiency at 10% load for single voltage EPS 

The figures from the database show that 96% of EPS except low voltage reported efficiency at 
10% load. Those not reporting were almost all under 10W. For low voltage EPS the database 
shows that 70% reported efficiency at 10% load. Those not reporting were all under 7.5W. All 
of a sample of 46 adaptive EPS reported efficiency at 10% load. 

115 

 
 
 
 
Q.  1.3  To  what  extent  can  the  achieved  improvements  be  attributed  to  the  EPS  ecodesign 
requirements?  

The EPS performance data shows that in the majority of cases the manufacturer reported data 
respects  the  requirements  of  the  regulation.  This  improved  performance  compared  to  that 
observed  before  the  regulation  was  in  place  can  be  attributed  to  regulatory  developments. 
However, it is hard to disentangle how much of this change is due to the EU regulation and 
how much to the US DoE requirements.  

The EU and US markets for appliances powered by an EPS are of a comparable size. This is 
likely to mean that need to comply with both sets of regulatory requirements will have had a 
comparable impact on manufacturers. It is likely to be the case that because both the EU and 
US requirements are aligned, it provides a stronger incentive for equipment manufacturers to 
ensure compliance with both and also reduces their cost to do so.  

The regulation and the US DoE requirements align with the levels that had been established 
earlier  in  the  EU  Code  of  Conduct.  This  would  have  provided  manufacturers  with  a  prior 
indication on a desirable and achievable level of performance. This may well have meant that 
manufacturers  had  a  sufficient  period  to  explore  designs  compliant  with  these  levels  and  to 
optimise them thus facilitating their introduction to the market.   

Q.  1.4  Has  the  required  energy  efficiency  information  been  made  available  to  consumers? 
How? 

Figure  38  illustrates  the  observation  that  the  information  provided  on  EPS  is  sometimes 
confusing and often unreadable. This is primarily because: 

It contains excessive text and data; 

• 
•  Very small text size (sometimes even smaller than 1mm); 
•  Colour used makes it difficult to read (e.g. grey over black, pale grey over white). 

For adaptive EPS sometimes very complex information is provided. This can include up to 15 
lines of text with lots of technical data for multiple-output adaptive EPSs. The range of power 
combinations can become a complex matrix that is difficult for the consumer to understand. 

Figure 38 - Information provided on EPS (source: Flavio Cucchietti) 

2. How successful has the regulation been in achieving or progressing towards its objectives? 

The answers to Q.1. show that the majority of EPS comply with the regulation’s requirements 
for no-load and active-mode energy efficiency by a comfortable margin. Based on these data 

116 

 
 
 
 
the following questions explore whether the expected outcomes, as a result of requiring more 
energy efficient EPS, have been achieved. 

Q. 2.1 Do the electricity savings match the expectations from the Impact Assessment? 

The  electricity  savings  that  have  been  achieved  are  estimated  based  on  the  observed 
manufacturer  declarations  of  active  and  no-load  efficiency  from  the  database.  Figure  39 
shows the comparison for active efficiency. The expected efficiency by class for sales in the 
year 2025 as shown in the EIA is shown in the first column. The second column shows how 
far  products  in  each  class  have  over-complied  with  the  requirements  in  the  regulation.  The 
third  column  shows  the  expected  energy  saving  for  each  product  class  and  the  fourth 
estimates the additional savings beyond those expected. 

Figure 39 - Comparison of reported with expected active efficiency electricity losses by product class (TWh) 

As  shown,  there  is  a  modest  and  comparable  over-compliance  in  most  EPS  classes.  The 
largest contributor to the over-achievement comes from EPS in the 10-12W category, but this 
is because they constitute the largest stock of EPS. Overall, there has been an approximately 
13%  extra  energy  savings  in  active  mode  compared  to  the  expectations  of  the  previous 
impact assessment as now represented in the EIA. 

Figure  40  shows  the  same  comparison  for  no-load  losses.  The  first  column  shows  the 
expected  no-load  loss  by  class  in  the  EIA  as  a  result  of  the  regulation’s  requirements.  The 
second  column  shows  how  far  products  in  each  class  have  over-complied  with  the 
requirements in the regulation. The third column shows the expected no-load energy loss for 
each product class and the fourth estimates the additional savings beyond those expected. 

117 

EIA expected efficiency of salesDatabase Δ%pts to regulated for groupEIA active electricity losses (TWh)Additional savings (TWh)LV2.02%Exc LV1.04%LV2.64%Exc LV1.42%LV3.05%Exc LV0.91%LV2.31%Exc LV0.91%d. EPS 15-20 W (e.g. portable devices, portable game consoles)Exc LV85.0%1.56%0.03890.00LV1.34%Exc LV0.98%f. EPS 30-65 W, multiple-V (e.g. multi-device univ. chargers)83.3%N/A0.134N/Ag. EPS 30-65 W (e.g. high-end notebook computers)Exc LV88.5%1.66%0.0800.01h. EPS 65-120 W (e.g. high-end notebook computers)Exc LV88.5%1.76%0.1060.02i. EPS 65-120 W, multiple-V (e.g. stationary game consoles)86.0%N/A0.166N/ATotal9.61.2413%0.0650.6470.5050.5360.010.090.060.067.3371.00e. EPS 20-30 W (e.g. notebook computer)b. EPS 6-10 W (e.g. tablets, smart phones etc.)a. EPS ≤ 6 W (e.g. mobile phone)73.7%81.9%87.3%j. EPS 12-15 W (e.g. loudspeakers, sound systems)84.1%c. EPS 10-12 W (e.g. small network equipment, set-top boxes) 83.1% 
 
 
Figure 40 - Comparison of reported with expected no-load electricity losses by EPS class (TWh) 

It  is  important  to  note  that  significant  no-load  benefits  were  only  assumed  in  the  previous 
analysis for four of the product classes i.e. a, b, c and d shown in the table. In view of that the 
significantly lower no-load consumption in the other product classes is not assumed to lead to 
any increased energy savings. For the categories where there is an impact, this amounts to a 
44% additional energy saving compared to that estimated in the impact assessment.  

It should be noted that the total no-load energy losses amount to only 5% of the active losses. 
In view of that, the significantly better no-load performance would only make about a further 
1.5%  contribution  to  the  overall  energy  savings  on  top  of  the  active  efficiency 
improvement.  

Taken  together  the  impact  of  the  better  performance  on  active  and  no-load  performance 
should  deliver  an  additional  1.4  TWh  of  electricity  savings  per  year  compared  to  what  had 
been expected. This means that the overall losses from EPS in 2025 would be reduced by 
around 14% compared to the losses expected. 

Q. 2.2 Do the GHG savings match the expectations from the Impact Assessment? 

Electricity GHG intensity 

The evolution of EU climate policy has led to stricter climate related requirements and a more 
rapid  decarbonisation  of  the  electricity  generating  sector  than  was  assumed.  The  Impact 
Assessment assumed a GHG intensity decreasing from 0.43 Mt CO2/TWh in 2000 to 0.39 Mt 
CO2/TWh in 2016 and to 0.34 Mt CO2/TWh by 2030. As can be seen in Figure 41 the actual 
trajectory observed from 2000 is considerably below that assumed in the impact assessment 
and the expected future values are far lower than had been assumed. The % reduction in GHG 
savings due to this in each year is shown in the last row. 

118 

EIA stock no-load power (W)No-load over compliance for group (W)EIA no-load electricity losses (TWh)Additional no-load savings (TWh)a. EPS ≤ 6 W (e.g. mobile phone)0.090.0240.0280.010b. EPS 6-10 W (e.g. tablets, smart phones etc.)0.090.0410.2700.120c. EPS 10-12 W (e.g. small network equipment, set-top boxes) 0.090.0460.0560.029j. EPS 12-15 W (e.g. loudspeakers, sound systems)0.090.0360.0000.000d. EPS 15-20 W (e.g. portable devices, portable game consoles)0.10.0350.0100.004e. EPS 20-30 W (e.g. notebook computer)0.090.0370.0000.000f. EPS 30-65 W, multiple-V (e.g. multi-device univ. chargers)0.3None assessedg. EPS 30-65 W (e.g. high-end notebook computers)0.180.0600.0000.000h. EPS 65-120 W (e.g. high-end notebook computers)0.180.1170.0000.000i. EPS 65-120 W, multiple-V (e.g. stationary game consoles)0.3None assessedTotal0.40.1644% 
 
 
 
 
Interpolated IA assumed 
Mt CO2/TWh 
Electricity generation  
Mt CO2/TWh 
Source 

Reduction 
in  GHG 
savings compared to IA 

2000 

0.43 

2005 

0.418 

2010 

2015 

2020 

2021 

2025 

2030 

0.405 

0.393 

0.376 

0.372 

0.358 

0.34 

0.394 

0.379 

0.335 

0.314 

0.229 

0.275 

0.179 

0.90 

EEA GHGs emission intensity of electricity generation 

REPOWER 
projection 

EU 

20% 

39% 

26% 

50% 

74% 

Figure 41 - Observed and projected electricity GHG intensity 

As  Figure  41  shows,  in  2021  the  actual  GHG  intensity  of  EU  electricity  generation  was 
around  26%  lower  than  that  projected  in  the  IA.  As  a  result,  the  GHG  savings  per  unit  of 
energy saved will be that much lower than were projected. 

Q. 2.3 Do the primary energy savings match the expectations from the Impact Assessment? 

Primary Energy Factor (PEF) 

A  PEF  of  2.5  was  used  in  the  IA  to  calculate  the  primary  energy  savings  based  upon  the 
avoided electricity use as set out in the Energy Efficiency Directive (EED)55 Annex IV. When 
the  EED  was  revised  in  2018  the  PEF  was  changed  to  2.1  with  effect  from  the  end  of  that 
year.  The  actual  primary  energy  factor  of  electricity  generation  has  continued  progressively 
decreasing  and  is  projected  to  decrease  further  to  2030  as  shown  in  Figure  42  below.  As  a 
result,  the  PEF  has  again  been  revised  to  1.956  from  the  end  of  2022.  The  change  in  PEF 
results in lower primary energy savings than projected as shown in the last row. 

Electricity PEF 
Source 
Reduction  in  primary  energy 
savings due to lower actual PEF 

2030 
2015 
2.40 
1.60 
Support to Primary Energy Factors Review 

2025 
1.87 

2020 
2.12 

4% 

15% 

25% 

36% 

Figure 42 - Electricity PEF from review support study 

Compared to the assumed PEF of 2.5 used in the IA, the use of a PEF of 2.1 would result in 
only  84%  of  the  estimated  primary  energy  savings  for  the  same  level  of  electricity  saved. 
With the PEF of 1.9 effective from 2023, the estimated primary energy savings would be only 
76% of those calculated previously.  

Based  on  the  calculated  PEF  values  shown  in  Figure  42,  the  PEF  value  for  2022  can  be 
estimated by interpolation as 2.02. In view of this primary energy savings in 2022 will have 
been 81% of the estimated primary energy saved per unit electricity saved. 

Q.  2.4  Do  the  consumer  energy  cost  savings  match  the  expectations  from  the  Impact 
Assessment? 

Electricity prices 

Electricity prices used in the impact assessment were obtained from the PRIMES 2016 model 
(scenario REF2015f). The values used (2015 prices) are shown in Figure 43 below:  

55 Directive 2012/27/EU. 
56 Commission Delegated Regulation (EU) 2023/807 

119 

 
 
 
 
 
 
 
 
 
 
Households. €/kWh 

% 

Services.  €/kWh 

% 

Final electricity price. €/kWh 

2010 

0.175 

75% 

0.151 

25% 

0.169 

2015 

0.194 

76% 

0.160 

24% 

0.186 

2020 

0.207 

76% 

0.174 

24% 

0.199 

2025 

0.213 

75% 

0.180 

25% 

0.205 

2030 

0.217 

76% 

0.183 

24% 

0.208 

Figure 43 - Electricity prices assumed in the previous Impact Assessment 

The  recent  Russian  aggression  against  Ukraine  has  led  to  energy  market  consequences  and 
substantially higher electricity prices in 2022. Prices had already been rising in 2021.  

2010 

2015 

2020 

2021 

2022 

Households EU27 2.5MWh<5MWh inc. taxes and 
charges €/kWh                                           

0.175 

0.208 

0.213 

0.228 

0.268 

Assumed % of price composition 

75% 

76% 

76% 

76% 

76% 

Non-household EU27 500MWh<2GWh inc. taxes 
and charges €/kWh                                     

0.128 

Assumed % of price composition 

Final electricity price €/kWh 

Final electricity prices €2015/kWh 

25% 

0.163 

0.175 

0.144 

24% 

0.193 

0.193 

0.156 

24% 

0.199 

0.188 

0.167 

24% 

0.213 

0.196 

0.236 

24% 

0.260 

0.219 

Figure 44 - Eurostat data on EU 27 electricity prices 

Figure  44  shows  Eurostat  data  for  EU27  household  and  non-household  electricity  prices. 
When deflated to €2015 it can be seen that outturn electricity prices have been quite similar to 
those  assumed  in  the  impact  assessment  for  the  period  2015  to  2025.  Figure  45  shows  the 
percentage variation between the IA assumed prices and the outturn.  

Figure 45 - Percentage variation in outturn electricity prices versus IA assumptions 

As a result, consumer electricity costs savings will have been slightly lower per kWh saved 
than  expected  in  2020  and  2021  and  slightly  higher  than  expected  in  2022.  In  view  of  the 
small deviation and the unexpected events in 2022 these do not point to any significant error 
in the underlying assumptions. From 2022 onwards the consumer savings will continue to be 
slightly higher per kWh saved. 

Q. 2.5 Are their other unexpected outcomes from the regulation? 

As  shown  by  manufacturers'  information  and  NDT  results,  the  performance  of  most  EPS 
matches the objectives of the Regulation and for some goes beyond its requirements. 

While the Regulation doesn’t have any material efficiency requirements, Figure 46 shows that 
recent  EPS  models  using  GaN  (green  circles)  have  a  higher  material  efficiency  than  EPS 
using conventional technologies (yellow circles).  

120 

2010201520202021202220250.20020.2014Eurostatfinalelectricityprices €2015/kWh0.1750.1930.1880.1960.219Outturn variation in %3.6%3.8%-5.5%-2.1%8.7%Interpolated0.169Impact Assessment final electricity price €2015/kWh0.1860.1990.205 
 
 
  
 
 
 
 
 
 
 
Figure 46 - Material efficiency of adaptive EPS 

Figure 47 shows that single voltage EPS (rightmost white bars) have a much lower material 
efficiency than adaptive EPS. 

Figure 47 - Material efficiency of adaptive and single voltage EPS 

Improved material efficiency contributes to lower consumption of materials and the need for 
less  end-of-life  treatment  and  therefore  lower  environmental  impacts  from  these  life  stages. 
Lower weight also results in reduced GHG and pollutant emissions during transport.   

Economic efficiency (cost/watt) was not an objective of the regulation, but this indicator gives 
some  useful  insights.  To  assess  the  price57  per  rated  power  (W),  Power  on  the  y  axis  is 
mapped against €/W on the x axis in Figure 48. Both GaN and conventional EPS show a large 
degree  of  variability  in  €/W.  However,  €/W  is  in  the  same  range  for  GaN  EPS  as  Silicon-
based  EPSs,  which  implies  that  there  is  no  cost  increase  with  GaN.  This  was  validated  by 
consultation with component manufacturers. 

This illustrates that technological progress, (replacing Si with GaN) and the higher efficiency 
associated  with  it  is  economically  viable  and  should  lead  to  lower  consumer  prices  for  the 
same  rated  output  power.  The  latter  is  only  relevant  for  unbundled  EPS  when  bought 
separately as a replacement EPS or for a product which is not supplied with an EPS. There is 
no guarantee this price saving will be passed to the consumer. 

57 All prices used here are B2C end price (VAT included). 

121 

 
 
 
 
 
Figure 48 - Economic efficiency of the tested EPS 

3. What factors have contributed to or hindered their achievement? 
3.1 To what extent have the ecodesign requirements been sufficient to contribute to improving 
the performance of EPS and meet minimum energy efficiency requirements? (MEErP Task 6. 
7) 

As illustrated in the answers to Q 1.1 and 1.2. the ecodesign requirements have contributed to 
improve  the  energy  efficiency  of  EPS.  However,  for  no-load  consumption,  there  remains  a 
larger margin for further improvement. The US EPS regulations have also contributed to the 
improvement  of  EPS  energy  efficiency  and  thus  through  spillover  effects  may  have 
contributed to achieving the objectives of the EU Regulation. 

3.2  Have  there  been  EPS  technological  improvements  that  contributed  to  increased  energy 
efficiency?  

A key technological development is pulse-width modulation which is also used in switching 
power  supplies,  one  of  the  most  common  examples  of  power  conversion.  Switching  power 
supplies  are  the  type  used  to  power  virtually  all  personal  computers,  mobile  devices,  and 
appliances that run on DC. Basically, the input AC voltage is converted to DC, and then that 
DC  is  “chopped”  into  a  high-frequency  alternating-current  square  wave.  This  chopping  is 
done by power transistors, which create the square wave by switching the DC on and off. The 
square wave is applied to a transformer that changes the amplitude of the wave to produce the 
desired  output  voltage.  To  get  a  steady  DC  output,  the  voltage  from  the  transformer  is 
rectified and filtered. 

Advances in semiconductor technology, in particular gallium nitride (GaN), is another reason 
for  improvement  in  power  electronics.  It  is  one  of  two  semiconductors—the  other  being 
silicon carbide (SiC)—that have begun displacing silicon-based electronics in enormous and 
vital  categories  of  power  electronics.  GaN  and  SiC  devices  perform  better  and  are  more 
efficient  than  the  silicon  components  they  are  replacing.  This  technological  progress  (GaN 
technology) and the respective cost reductions have encouraged the adoption of GaN, which 
offers higher energy efficiency. GaN’s main advantage is its extremely high electron mobility. 
Electric current, the flow of charge, equals the concentration of the charges multiplied by their 

122 

EPS power rating(W)EPS priceper Watt ratedoutputpower (€/W) 
 
 
velocity. So you can get high current because of high concentration or high velocity or some 
combination of the two.  The GaN transistor is  unusual  because most of  the current  flowing 
through  the  device  is  due  to  electron  velocity  rather  than  charge  concentration.  What  this 
means in practice is that, in comparison with Si or SiC, less charge has to flow into the device 
to switch it on or off. That, in turn, reduces the energy needed for each switching cycle and 
contributes to  high  efficiency. GaN’s high  electron mobility allows switching  speeds on the 
order of 50 volts per nanosecond. That characteristic means power converters based on GaN 
transistors operate efficiently at frequencies in the multiple hundreds of kilohertz, as opposed 
to about 100 kilohertz for silicon or SiC. 

Taken  together,  the  high  efficiency  and  high  frequency  enable  power  converters  based  on 
GaN devices to be smaller and lighter. High efficiency means smaller heat sinks and operation 
at high frequencies means that the inductors and capacitors can be very small too. 

Starting  in  2019,  GaN-based  wall  chargers  became  available  commercially  from  companies 
such  as  GaN  Systems,  Innoscience,  Navitas,  Power  Integrations  and  Transphorm.  The  high 
switching speeds of GaN coupled with its generally lower costs. have made it the incumbent 
in  lower-power  markets  (25  to  500W),  where  these  factors,  along  with  small  size,  are 
paramount. 

3.3  What  external  factors  have  affected  progress  towards  the  objectives,  and  how  are  they 
linked to the EU intervention? 

In additional to technological progress, other EU related external factors which have affected 
progress  towards  the  objectives  are:  electricity  price  changes  due  to  geopolitical  reasons; 
lower GHG emission intensity of electricity generation and a lower Primary Energy Factor. In 
addition to these is the possible impact of the US regulations. 

The effect of each of these factors on achieving the objectives of the Regulation are shown in 
the  answers  to  Q2.  A  summary  of  the  impact  on  the  outcomes  from  each  factor  and  the 
direction of the impact it has caused is shown in the table below. 

Factor  Electricity 

price 

Electricity 
GHG intensity 

EU PEF 

US regulation  

Impact on: 

Electricity savings 

GHG savings 

Primary 
savings 

energy 

N/A 

N/A 

N/A 

Consumer  energy 
cost savings 

IMPACT ˄ 

N/A 

IMPACT ˅ 

N/A 

N/A 

IMPACT ≈ 

N/A 

N/A 

IMPACT ˅ 

N/A 

N/A 

N/A 

IMPACT ≈ 

Table 36 - Impacts of EU related external factors 

4. How effective has the implementation and enforcement of the Regulation? 

There  is  not  sufficient  market  surveillance  information  available  from  Member  States.  The 
ICSMS  database  only  has  data  from  Germany.  Information  was  received  directly  from 
Denmark. Despite reminders sent to Member States seeking more information, no additional 
information was received about implementation and enforcement in other Member States. 
4.1 Status of market surveillance in MS? Does it differ compared to other products regulated 
by the Ecodesign Directive? 

123 

 
 
From a sample of 258 EPS units tested in Germany, 57% appeared to be non-compliant. 

Figure 49 - Compliance rate of the EPS (Source: ICSMS data) 

In 2020. Denmark tested 117 EPS for compliance with  both  Regulation (EU) 278/2009  and 
Regulation (EU) 2019/1782, but they were not reported in the ICSMS database. 48 EPS failed 
in compliance for no-load, while 33 failed for average efficiency threshold. Out of these, 22 
failed  on  both  while  others  were  on  one  of  the  thresholds.  Some  EPS  also  failed  for  the 
threshold  levels  of  Regulation  (EU)  278/2009:  8  for  no  load  and  6  for  average  efficiency 
threshold; out of these, 3 failed for both. 

Market  surveillance  for  EPS  appears  to  be  less  active  than  for  other    household  goods. 
Projects  such  as  EEPLIANT  (https://eepliant.eu),  EEPLIANT2  and  EEPLIANT3  have 
focussed on market surveillance of products such as lamps, printers, space heaters, household 
refrigerating appliances,  professional  refrigeration products,  comfort  fans,  household  tumble 
dryers, water heaters and hot water storage tanks, ventilation units, lighting products and local 
space heaters.  

4.2 Is there non-compliance with the Regulation requirements? If so, how much of that is due 
to poor enforcement? 
As shown in section 1, based on manufacturer data, EPS largely comply with the regulation’s 
no-load and active efficiency requirements as well as the marking of efficiency at 10% load. 
The German example showed significant non-compliance for the products sampled. However, 
since sampling is risk based, the non-compliance rates observed cannot be assumed to be the 
same  for  the  whole  market.    The  German  MSA  stated  that  the  reasons  for  non-compliance 
were: 

•  Non-conformities with power consumption at no load; 
•  Non-conformities with requirements on average active efficiency; 
•  Non-conformities with requirements for information on the nameplate; 
•  Non-conformities with requirements on published data; 
•  Failure to achieve the output power or output current advertised on the nameplate 
•  Failure  to  comply  with  the  "efficiency  at  low  load  (10%)"  declaration  by  the 

manufacturer; 

•  Non-compliance with "Article 2 (Definitions)", as some manufacturers claim that their 
power supply - for example installed in a socket cube - is not (at all) covered by the 
EPS regulation; 
•  Missing address; 
•  Contractual relationship between importer-manufacturer not clear. 

Efficiency 

124 

 
 
 
Q4. Are the costs related to the Regulation proportionate to the benefits? 

The  administrative  and  regulatory  burdens  are  similar  to  the  prior  Regulation  (EC)  No 
278/2009.  The  measurement  of  active  average  efficiency  follows  the  same  test  procedure 
(same test setting) as before and there are therefore no additional test costs. The new element 
in Regulation (EU) 2019/1782 is the reporting for the measurement at 10% load point, which 
led to  minimal  additional  test costs (estimated at a maximum of €100 per model) given the 
synergies with active average efficiency testing. Additional cost per EPS will not have been 
more than a few cents.  

There has been no significant price increase (especially B2B) during the last few years due to 
technological progress58. Minor cost increases, if any, may have been absorbed by industry or 
OEMs  who  supply  the  EPS  with  their  products.  However,  power  electronics  component 
prices have increased recently (perhaps temporarily) due to chip shortages. The market trend 
is towards power supplies with increased efficiency (i.e. more benefits) and cost reduction59. 
This would mean that higher efficiency is leading to lower energy losses without any increase 
in costs to consumers.  

The factors linked to the intervention which could influence efficiency are the costs related to 
market  surveillance  and  enforcement  costs.  While  they  would  be  similar  to  the  2009 
regulation,  it  seems  that  little  market  surveillance  means  those  costs  were  not  incurred. 
Another factor which could influence the costs and benefits is the EPS lifetime. While in most 
cases, EPS outlive the product with which they were supplied, in case of breakdown (cheaper 
EPS), accident or loss, additional costs will be incurred by consumers, and often the EPS sold 
directly to consumers can be 2 to 3 times higher than the B2B cost.  

No specific inefficiencies have been identified. 

Competitiveness 

No substantial manufacturing of consumer EPS occurs in Europe. However. two of the major 
global market leaders in (power) electronic components Infineon and ST Microelectronics are 
from Europe. The latter is investing in the leading GaN manufacturer Exagan and expanding 
capacities. 

Regulation  has  had  no  observed  negative  impact  on  the  competitiveness  of  European 
suppliers  in  the  EPS  business  and  none  has  been  reported  in  any  interviews  or  feedback 
received. 

Relevance 
Q5. Does the Regulation correspond to the current needs of the EU? 

The scope and objectives of the intervention remain relevant over the implementation period. 
However,  many  more  products  are  entering  the  markets  (e.g.  products  with  charging  as  a 
secondary  function,  wireless  chargers,  e-bikes),  which  are  not  covered  by  the  scope  of 
Regulation (EU) 2019/1782, but which are powered by EPS or could be powered with these 
instead of an internal power supply 

Q  5.1  How  did  the  objectives  of  the  intervention  correspond  to  wider  EU  policy  goals  and 
priorities? 

58 Personal communication: Power integration. 
59 Yole Développement, 2021. 

125 

 
 
 
The objectives of the intervention correspond to wider EU policy goals, such as the EU Green 
deals and its climate targets. The overall ambition of the climate targets has increased along 
with demands for more energy savings and Regulation (EU) 2019/1782 contributes to energy 
savings and resulting GHG reduction. 
The  Circular  Economy  Action  Plan  calls  for  measures  to  reduce  e-waste60  with  goals  like 
creating  the  right  to  repair  and  improving  reusability  in  general,  introduction  of  a  common 
charger and establishing a rewards system to encourage recycling electronics. Most EPS have 
a life longer than the products  with  which they  are delivered as  accessory, they continue to 
accumulate  in  households  and  often  become  e-waste.  About  25%  of  the  EPS  at  the  end  of 
their active use become part of e-waste. 

Circular economy aspects are not addressed by Regulation (EU) 2019/1782. 

Q 5.2 To what extent is the intervention still relevant in view of its objectives?  

How well do the (original) objectives of the intervention still correspond to the needs of the 
EU? 

The  intervention  remains  relevant  as  the  products  requiring  an  EPS  are  still  consumed  by 
society and new products requiring EPS are appearing on the market which is likely to lead to 
an increased demand and stock of EPS.  

The original objectives remain valid since energy and GHG savings remain a high priority for 
EU  policy.  However,  since  the  overall  policy  objectives  have  been  strengthened,  this  might 
justify a higher ambition level for example through higher average active efficiency, lower no 
load power consumption, and energy efficiency requirements at low load (10%), which is an 
aspect where no limits were defined in the existing Regulation. 

Q 5.3 To what extent do the needs/problems addressed by the intervention continue to require 
action at EU level? 

While the market seems to respond to the Regulation based on manufacturer data, there is not 
sufficient  market  surveillance  information  to  provide  assurance  that  the  intervention  is 
effective in fully delivering the results expected.  

Q 5.4 How well adapted is the intervention to the technological progress that has happened 
since its introduction?  

How well adapted is the intervention to social. and environmental changes? 

The main change in terms of technological development is the arrival on the market of new 
products  requiring  EPS.  Many  of  these  products  may  be  outside  the  scope  of  the  current 
Regulation and that would require a change in the intervention for them to be addressed.  

In  terms  of  efficiency,  technological  progress  shows  that  EPS  with  much  higher  efficiency 
can  be  produced  at  almost  the  same  cost  (manufacturer  data  shows  EPS  already  perform 
better than the efficiency limits of the Regulation), the intervention is no longer well adapted 
and could be revised to better align with existing and upcoming technologies.  

In  terms  of  interoperability,  despite  the  potential  of  a  USB-PD  ‘universal  charger’  solution. 
the global market for power electronics in the consumer market continues to grow, according 

60 About half a billion chargers for portable devices shipped into Europe each year, generate 11 000 to 13 000 
tonnes out of total 4.7 million tons of e-waste generated in the EU. 
https://www.europarl.europa.eu/news/en/press-room/20220429IPR28224/common-charger-parliament-commits-
to-reducing-electronic-waste. 

126 

 
 
 
to leading market research companies (Yole Développement. 2021). The existence of USB / 
USB-PD has not led to EPS reuse by consumers at a large scale. The testing of the new USB 
standards (USB-PD) need to be reflected in the regulation.  

Q.  5.5  Are  the  regulation’s  requirements  sufficiently  stringent  in  view  of  developments  in 
other jurisdictions? 

There  is  a  global  shift  toward  IEC  energy  efficiency  level  VI,  Figure  50  shows  that  this  is 
becoming a de-facto standard. Regulation (EU) 2019/1782 requiring this level of performance 
followed legislation in the US and Canada.  

Figure 50 - Evolution of Regulations in the EU, US, Australia and Canada61 

In  the  US,  DoE  has  done  extensive  work  to  review  the  EPS  efficiency  limits,  with  detailed 
cost  curves  and  different  thresholds.  DoE  recently  initiated  the  process  to  revise  the  US 
Energy  Conservation  Standards  for  External  Power  Supplies.  A  notice  of  proposed  rule 
making has now been published. For single-voltage EPS this is essentially aiming at the tier 2 
level  of  the  EU  CoC.  For  multiple  voltage  EPSs,  DoE  envisages  raising  the  efficiency 
requirements  by  as  much  as  2.5%  and  the  no-load  power  consumption  limits  have  been 
significantly  reduced.  These  developments  support  the  view  that  there  is  scope  for 
strengthening the EU Regulation. 

The  test  procedure  for  External  Power  Supplies  (10  CFR  Part  430)  specifying  test 
requirements  has  been  effective  since  19  September  2022,  e.g.  for  adaptive  external  power 
supplies that conform to USB-PD specifications. Also, the active average efficiency to meet 

61 https://www.cui.com/efficiency-standards. 

127 

 
 
 
 
minimum  requirements  at  the  highest  and  lowest  supported  voltage  levels.  This  test  will  be 
mandatory for product testing starting 15 February 2023. 

Q 5.6 How relevant is the intervention to EU citizens? Will it continue to be relevant for them 
in the near future? 

Consumers  are  probably  unaware  of  the  energy  efficiency  of  EPS  and  are  unlikely  to  give 
much consideration to it when making a purchase, especially since most EPS are sold bundled 
with products. Despite this, given the lengthy periods for which most EPS will be used, the 
energy  and  cost  savings  for  consumers  are  non-negligible.  Technological  development 
suggestions  that  there  could  be  further  savings  to  be  realised  in  the  future,  that  would  be 
unlikely to materialise in the absence of regulatory requirements.   

Consumer’s  need  for  information  on  the  characteristics  and  performance  of  EPS  remains 
valid. Even with multi-voltage EPS it is still important to have EPS with adequate power for 
the  device.  As  more  devices  and  EPS  are  powered  via  interchangeable  connectors  such  as 
USB-C,  the  need  for  information  increases  as  the  same  EPS  can  be  used  with  multiple 
products.  This  need is  likely  to  increase as more devices can be interchanged with  different 
EPS and the number of different products requiring an EPS grows.  

In  view  of  these  considerations.  the  Regulation  remains  relevant  for  providing  relevant 
information to consumers in order to choose a proper EPS and for providing them with energy 
and costs savings that they would otherwise forego. 

Q6. How Flexible is the Regulation with regard to other policies and new issues? 
The scope of the Regulation is fixed (by its Annex I) and doesn’t therefore provide flexibility 
to  include  new  products  which  use  an  EPS.  Similarly,  it  has  no  flexibility  in  relation  for 
example to unbundling EPS from products. 

Figure 51 - Outlook on synergies of different legal acts (as regards interoperability) 

The regulation does not contain any specific elements related to the common charger initiative 
and RED (see Figure 51). The regulation does not specifically identify (e.g. through product 
marking)  the  harmonised  EPS  that  facilitates  interoperability.  Interoperability  has  the 
potential  to  reduce  consumer  need  to  purchase  EPS  and  increase  consumer  convenience 
through ensuring that the same EPS can be used with multiple products. 

Coherence 

128 

EPS RegulationRadio Equipment Directive 
 
 
 
Q. 7 How coherent is the EU intervention? 

Q  7.1.  To  what  extent  is  the  intervention  coherent  internally,  with  other  interventions  with 
similar objectives and with wider EU policy? 

The objectives of the measure were to establish ecodesign requirements for EPS in in the light 
of technological progress made since Regulation (EC) No 278/2009. The articles and annexes 
of the Regulation are considered to be coherent. 

External coherence with related measures was assured with Regulation 1275/2008 on standby 
and off-mode conditions.  

The  Regulation  lacks  any  requirements  related  to  circular  economy  and  material  efficiency 
and therefore opportunity for improving coherence remain in this area. 

The intervention is considered coherent with wider EU policies with regard to energy saving 
and GHG emissions reduction. No conflicting objectives or requirements have been observed. 

Q. 7.2 To what extent is the intervention coherent with international obligations? 

The intervention applies similarly to intra-EU and extra-EU suppliers and applies to the EU 
Single  Market  only.  A  level  playing  field  for  intra/extra  EU  suppliers  is  ensured,  and  the 
regulation passed WTO scrutiny in the period before publication in 2019. 

EU-added value 
Q8. What is the EU added value of the intervention? 
Q.  8.1  What  is  the  additional  value  resulting  from  the  EU  intervention.  compared  to  what 
could reasonably have been expected from Member States acting at national and/or regional 
levels? 

There is no specific intervention at Member state level targeting EPS. By having an EU-wide 
measure,  suppliers  have  the  same  set  of  (harmonised)  requirements  across  the  whole  EU 
Single  Market.  This  removes  the  risk  of  having  to  perform  different  tests  and  other 
performance  assessments  and  having  to  meet  different  national  requirements  as  regards 
labelling when placing products on national markets.  

For  consumers,  the  intervention  brings  added  value  as  it  provides  information  on 
characteristics  for  choosing  an  EPS.  For  suppliers  the  added  value  is  that  they  can  use  the 
same  models  for  the  entire  EU  market  and  are  not  required  to  prepare  for  different 
requirements at national level. 

For market surveillance, the added value of the EU measure lies in the mutual recognition of 
verification  assessments  performed  in  other  countries.  National  authorities  do  not  need  to 
perform verification tests on products already verified by other authorities. 

Q. 8.2 What would be the most likely consequences of stopping or withdrawing the existing 
EU intervention? 

If  the  EU  ecodesign  requirements  were  stopped  it  may  prompt  Member  States  to  develop 
requirements  themselves.  This  would  detrimentally  affect  the  functioning  of  the  EU  Single 
Market. 

129 

 
 
 
 
Evaluation Annex IV. Overview of benefits and costs  

The expected achievements at the time of the 2018 impact assessment were:  

The Regulation  applied from April 2020. Therefore, the comparison of its actual impacts to 
the assumptions in the Impact Assessment can only be done for the period 2020-2023. 

Impact of various parameters on the expected impacts 

Energy efficiency of EPS 

As  demonstrated  in  Q1.4,  actual  electricity  savings  have  exceeded  those  expected  since  on 
average  efficiency  exceeds  the  minimum  requirements.  Since  the  2018  impact  assessment 
calculated  the  annual  savings  on  the  basis  that  the  whole  stock  of  EPS  would  have  been 
replaced with EPS meeting the new requirements, this is assumed to be achieved by 2025 at 
the earliest. 

Figure  52  shows  the  annual  electricity  savings  estimated  in  the  IA  for  the  period  2020  to 
2030. The preferred option is shown in grey. 

Policy options 

1 BAU 

2 Global alignment 

3 Ambitious EU measure 

Saving vs. BAU, TWh/year 

2020 

- 

1.40 

1.40 

2025 

- 

3.96 

4.31 

2030 

- 

4.26 

4.57 

4 Very ambitious EU measure 

6.25 
Figure 52 - IA estimation of the electricity savings from the policy options 

5.71 

1.40 

Based on the manufacturer database and the calculations shown in Q1.1, it is estimated that 
when  the  EPS  stock  is  fully  replaced  an  additional  1.4TWh  of  electricity  savings  will  be 
achieved.  If  this  is  conservatively  only  assumed  to  be  the  case  by  2030  it  would  represent 
33%  extra  savings.  Assuming  that  the  increase  in  savings  is  proportionate  each  year,  the 
additional  electricity  savings  would  be  1.3TWh  in  2025  and  amount  to  a  total  of  5.26TWh 
based on the same assumptions as in the IA. 

BREXIT  

The  UK  leaving  the  EU  in  2021  had  the  effect  of  reducing  the  overall  size  of  the  market 
covered by the Regulation. Nevertheless, the effects of the Regulation have been maintained 
in the UK after it ceased to be a member, as the new post-BREXIT requirements have been 
aligned with the EU rules62. The BREXIT factor used in the EIA to account for the UK share 
of EPS sales is 15%.  

62https://www.gov.uk/government/consultations/ecodesign-requirements-for-external-power-supplies-draft-
regulation 

130 

Impacts vs BAU202020252030Electricity savings (TWh)1.43.964.26GHG savings (Mt CO2eq/year)0.531.421.45Consumer electricity cost saving (€m/year)280810885Consumer expenditure saving (€m/year)169705787 
 
 
 
If the UK share of EPS sales are removed from the estimation of its benefits, then these can be 
assumed to be to be 15% lower. This would reduce the estimated 5.26TWh annual electricity 
savings in 2025 to 4.47TWh. 

Electricity GHG intensity 

Assumed Mt CO2/TWh 

Electricity generation Mt CO2/TWh 

Source 

2020 
2015 
0.376 
0.393 
0.229 
0.314 
EEA electricity generation GHG emission intensity 

2021 
0.372 
0.275 

2025 
0.358 
0.179 
REPOWER EU  

Reduction in GHG savings compared to IA 

20% 

39% 

26% 

50% 

Figure  53  below  shows  how  the  actual  GHG  intensity  of  EU  electricity  generation  has 
changed  compared  to  the  assumptions  used  in  the  IA.  This  shows  that  the  actual  GHG 
intensity is significantly lower than was assumed. 

Assumed Mt CO2/TWh 

Electricity generation Mt CO2/TWh 

Source 

2020 
2015 
0.376 
0.393 
0.229 
0.314 
EEA electricity generation GHG emission intensity 

2021 
0.372 
0.275 

2025 
0.358 
0.179 
REPOWER EU  

Reduction in GHG savings compared to IA 

20% 

39% 

26% 

50% 

Figure 53 - Assumed and outturn electricity GHG intensity 

The trend is less consistent than it would otherwise have been due to the impacts of COVID 
and the Russian aggression in Ukraine. Overall, it is clear that the GHG intensity is at  least 
25% lower than anticipated and may be as high as 30% lower for the period considered.  

Policy option 

PO1 BAU 

PO2 Global alignment 

PO3 Ambitious EU measure 

PO4 Very ambitious EU measure 

Reductions vs. BAU Mt CO2eq/year 

2020 
- 

0.53 

0.53 

0.53 

2025 
- 

1.42 

1.55 

2.05 

2030 
- 

1.45 

1.55 

2.12 

Figure  54  shows  the  annual  GHG  savings  estimated  in  the  IA  for  the  period  2020  to  2030. 
The preferred option is shown in grey. 

Policy option 

PO1 BAU 

PO2 Global alignment 

PO3 Ambitious EU measure 

PO4 Very ambitious EU measure 

Reductions vs. BAU Mt CO2eq/year 

2020 
- 

0.53 

0.53 

0.53 

2025 
- 

1.42 

1.55 

2.05 

2030 
- 

1.45 

1.55 

2.12 

Figure 54 - IA estimation of the GHG savings for the policy options 

In view of the lower outturn GHG intensity, the actual GHG savings will have been reduced 
compared to the assumptions. 

If the known 2021 GHG intensity is used with the energy savings achieved after accounting 
for  over-achievement  and  BREXIT,  then  in  2025  the  GHG  savings  would  amount  to 

131 

 
 
 
 
 
 
1.23MtCO2.  If,  however,  the  projected  GHG  intensity  from  REPOWER  EU  is  used  then  in 
2025 the GHG savings would be only 0.8MtCO2.  

Final electricity prices 

2015 

Assumed final electricity price. €/kWh 

0.186 

Actual final electricity prices €2015/kWh 

0.193 

2020 

0.199 

0.188 

Outturn change compared to IA 

+3.7% 

-5.5% 

2021 

0.200 

0.196 

-2% 

2022 

0.201 

0.219 

+9% 

Figure  55  below  compares  the  electricity  price  assumptions  used  in  the  IA  with  the  actual 
prices adjusted for inflation.  

2015 

Assumed final electricity price. €/kWh 

0.186 

Actual final electricity prices €2015/kWh 

0.193 

2020 

0.199 

0.188 

Outturn change compared to IA 

+3.7% 

-5.5% 

2021 

0.200 

0.196 

-2% 

2022 

0.201 

0.219 

+9% 

Figure 55 - Comparison of IA assumptions and outturn electricity prices 

Although the data do not cover the whole period and prices are not available for 2019, it can 
be  seen  that  there  does  not  appear  to  have  been  any  consistent  over  or  under  estimation  of 
prices. Nevertheless, electricity prices remain higher than before the energy crisis and so the 
+9% outturn in 2022 is assumed to continue into the future. 

The electricity cost savings estimated in the IA based on the estimated electricity that would 
be saved are shown in the table below: 

Policy options 

PO1 BAU 

PO2 Global alignment 

PO3 Ambitious EU measure 

PO4 Very ambitious EU measure 

Saving vs. BAU, €m/year 

2020 

2025 

2030 

- 

280 

280 

280 

- 

810 

882 

- 

885 

950 

1,169 

1,298 

Table 37 - Electricity cost savings 

In fact, total electricity savings in 2025 taking account of over-compliance and BREXIT are 
calculated to be 13% higher than estimated in the IA. The 9% higher electricity prices result 
in  consumer  savings  23%  higher  than  estimated  in  the  IA.  This  would  mean  that  consumer 
savings would be €997mln per year in 2025. 

Impact of the PEF 

To estimate the primary energy savings a Primary Energy Factor is used as set out in Annex 
IV of the Energy Efficiency Directive. At the time that the Impact Assessment was carried out 
the  PEF  value  was  specified  as  2.5.  This  means  that  the  primary  energy  savings  were 
calculated as being 2.5 times the final electricity savings. As the table below shows, the actual 
value  of  the  PEF  when  the  Regulation  applied  from  2020  onwards  was  around  2.1  and 
decreasing. 

2015 

2020 

2025 

2030 

132 

 
 
 
 
 
 
Actual electricity PEF 
Lower primary energy savings due to lower actual PEF 
Source: Support to Primary Energy Factors Review 

2.40 
4% 

2.12 
15% 

1.87 
25% 

1.60 
36% 

Table 38 - Primary energy savings as a function of the PEF 

The PEF value in 2020 was 15% lower than the value used in the IA and this was expected to 
increase to 25% lower by 2025. The future figures may be impacted by the same factors that 
influenced  the  GHG  intensity  of  electricity  generation.  Nevertheless,  it  seems  reasonable  to 
assume  that  the  PEF  will  have  been  at  least  15%  lower  than  was  assumed  having  a 
comparable  impact  on  the  actual  primary  energy  savings.  This  means  that  these  will  have 
been around 0.64 TWh lower per year than was estimated. 

Costs and employment impacts 

Because  it  was  not  possible  to  gather  any  data  on  the  costs  of  compliance  or  the  price  of 
products  regulated,  it  has  not  been  possible  to  make  any  revised  estimates  of  the  increased 
costs of the products or any consequent employment impacts. 

Evaluation Annex V. Stakeholder consultation – summary of comments relevant to the 
evaluation 

Stakeholder were invited to provide comments through a Call for Evidence covering the back-
to  back  evaluation  and  Impact  Assessment.  Only  stakeholder  comments  related  to  the 
evaluation are summarised below: 

Applia 

APPLiA note that for some products there might be a use case for 10% load operation. but for 
the majority of the EPS there is none or at best only during a limited timeframe. In preparing 
the previous IA the relevance of 10% load for certain  ICT equipment  was raised but  it also 
acknowledged the lack of relevance for EPS for battery operated devices. For these typically. 
EPS will shut off at 15%-20% load levels. USA DoE data states over 80% of EPS are used for 
battery charged devices. 

ECOS 

Raised  concern  over  limitations  of  “Back-to-back  evaluation”  procedure.  Concern  there  are 
insufficient opportunities for consideration of stakeholder comments. 

Note  analysis  currently  under  way  by  US  DOE  to  revise  their  EPS  efficiency  metric.  This 
implies that further savings should be possible.  

The Common Charger initiative means that EPS are increasingly likely to be used at a wide 
range  of  loading  levels  –  in  particular  at  lower  loading  levels.  EPS  typically  operate  at 
reduced efficiency at these lower loads.  

The scope of the regulation should be expanded to results in the best possible savings.  

EPS  and  cables  are  currently  marketed  using  a  range  of  current  (A),  power  (W)  and  cable 
features on packaging in a non-standard way that is confusing for consumers.  

There is a lack of information on EPS and cables once they are out of their packaging. Users 
may  have  identical-looking  EPS  with  different  power  ratings,  and  identical-looking  cables 
that offer different charging performance or functions. 

ITI 

133 

 
 
fact 

ITI  supports  voluntary  approaches  to  common  charging  solutions.  Recalls  that  the  2021  IA 
study says “the vast majority of mobile phones and EPS from major OEM manufacturers are 
in 
that  are  more 
interoperable. energy‐efficient and smart charging that can safely handle various power needs 
of different devices. Information requirements may be insufficient for EPSs which implement 
proprietary charging protocols in addition to USB-PD charging protocols. 

interoperable”.  Market  participants  have  provided  products 

IARU 

IARU draw attention to  the potential of switching power supplies to  contribute to  spectrum 
pollution. The recent evaluation of the EMC Directive covers this topic in detail.63 The last-
published  report64  by  EMC  MSAs  showed  56%  of  the  devices  tested  met  the  technical 
emissions compliance tests. It is hoped that more recent market surveillance reports will show 
greater compliance. EPS cables can act as an antenna adding to spectrum pollution. A lack of 
comprehensive  standards  for  cables  can  result  in  poor  quality  cables  being  used  in  the 
marketplace.  Testing  requirements  should  reflect  typical  use  cases  of  EPS  with  associated 
cabling.  

ANEC / BEUC 

The review of the EPS Regulation should assess it is successful in achieving its objectives. 

Believe that the scope in the Regulation’s Annex I is too limited. It should be complementary 
to the Ecodesign Regulation on smartphones and tablets and the ongoing Revision of Radio 
Equipment Directive.  

Important to see whether further efficiency improvements can be achieved at lower loads.  

Starkey Laboratories 

Power  supply  efficiency  and  environmental  regulations  should  be  harmonised  globally  to 
permit  use  of  products  around  the  world.  At  present  this  condition  is  met  by  the  Level  VI 
requirements.  If  a  higher  level  of  efficiency  is  required.  it  should  be  harmonised  with 
requirements in North America. Asia. and Australia. 

EU Citizens 

Estonia (citizen) Any ecodesign is useless if it is outdated or not implemented in the consumer 
world. 

63 Study on the evaluation of the Electromagnetic  Compatibility Directive 2014/30/EU (EMCD): final report, 
Publications Office, 2021. 
64  Report  on  the  Fifth  Joint  Cross-Border  EMC  Market  Surveillance  Campaign  on  switching  power  supplies 
(2012/2013). 

134 

 
 
 
 
 
 
 
 
ANNEX 8: THE SME TEST 

Identification of affected businesses 

The  EU  SME  Envoy  has  not  signalled  to  the  Commission  that  this  initiative  merits  close 
attention from an SME perspective. Nevertheless it is important to assess to what extent the 
initiative is relevant for SMEs. To provide answers to this question it is broken down into the 
following steps: 

– Are SMEs within the scope of the legislative initiative? 

Various sectors are likely to be impacted by the measures considered and SMEs in them will 
therefore also be impacted. 

The  primary  sector  to  be  impacted  is  the  manufacture  of  EPS.  EPS  are  to  a  high  degree 
largely  standard  commodity  products.  Their  manufacture  is  at  a  large  scale  and  no  SME 
manufacturer of EPS has been identified. While some design and research is performed in the 
EU. manufacture is mainly carried out in lower cost countries. 

The sales sector through which EPS are provided to end customers will contain SMEs. To the 
degree that the initiative impacts on the value of individual sales (either increasing it through 
technical  requirements  or  reducing  it  through  interoperability)  it  will  also  have  a  similar 
impact on SME turnover.  

SMEs will be users of EPS for their business operations. for example for IT equipment. They 
will be affected by the energy savings and potential to reuse EPS thereby avoiding purchase 
costs.  These  impacts  are  likely  to  scale  with  the  amount  of  such  equipment  in  use  and  be 
proportionate to benefits experienced in larger businesses. 

– Does the initiative specifically target SMEs? 

The initiative does not specifically target SMEs. 

– Will the SMEs be significantly impacted directly or indirectly by the legislative initiative?  

The two sectors where SMEs are likely to be most affected are in sales of EPS and their end 
use.  

In the case of the sales sector. EPS are relatively low cost and therefore any reduction in sales 
will  have  a  small  impact  on  overall  revenue.  As  an  illustration  the  Ecodesign  Impact 
Accounting  estimates  for  2030  that  business  revenue  from  the  sale  of  EPS  would  represent 
€3bn.  This  compares  to  total  sales  of  €240bn  for  other  electronic  products  regulated  under 
ecodesign  which  are  by  far  from  all  electronic  products  on  sale.  Since  the  initiative  would 
only lead to a partial reduction in the EPS sales. while partly increasing their cost the impact 
would be less than 1% of revenue. This change would take place over the replacement cycle 
of  products  or  EPS  meaning  it  would  be  likely  to  be  spread  over  some  ten  years.  It  can  be 
concluded that the impact on SMEs in this sector will not be significant. 

The scale of impact on SMEs purchasing EPS is the mirror image of that on SMEs in the sales 
sector. However. in addition SMEs using EPS will also benefit from the increased efficiency 
and  durability  of  EPS.  Added  together  these  savings  will  still  be  modest  and  will  likely  be 
comparable in proportion to the impacts on large businesses. 

135 

 
 
 
–  Are  SMEs  impacts  likely  to  be  more  substantial  than  on  other  companies.  for  example  in 
terms of adverse effects? 

There  is  no  reason  to  expect  that  SMEs  in  either  of  the  sectors  identified  will  be  more 
substantially impacted than larger businesses either for the positive or adverse impacts. 

Following  this  assessment  it  is  concluded  that  this  initiative  is  of  very  minor  relevance  for 
SMEs. In view of this no more detailed analysis of the impact on SMEs has been carried out. 

136 

 
 
 
 
 
ANNEX 9: COMPETITIVENESS CHECK  

1.  Overview of impacts on competitiveness 

Table  39  summarizes  the  impacts  of  the  preferred  policy  option  on  competitiveness  against 
the four dimensions as per qualitative screening: 

•  What  is  the  effect  on  cost  and  price  competitiveness?  (e.g.  impacts  on  compliance 

costs, cost of labour or capital, prices, consumer choice. etc.) 

•  What is the effect on the enterprises’ capacity to innovate? 

•  What might be the effect on the sector’s international competitiveness? (e.g. impacts 

on domestic versus foreign firms, trade, cross-border investment flows, etc.) 

•  What is the effect on SME competitiveness? 

Dimensions 
competitiveness 

of 

Impact of the initiative  

(++ / + / 0 / - / -- / n.a.)  

References  to  sub-sections  of  the  main 
report or annexes  

Cost 
competitiveness 

and 

price 

Between - and +   

6.2  to  6.4  and  8  in  main  part;  section  1 
and 2 in Annex 3 

Capacity to innovate 

+ 

6.2 and 8 in main part; section 1 in Annex 
3 

International 
competitiveness 

SME competitiveness 

End-product 
manufacturers.  
EPS manufacturers: 0 

Component 
manufacturers: + 

End-product 
manufacturers. 
Refurbishers: + 

EPS manufacturers: 0 

6.2 and 8 in main part; section 1 in Annex 
3 

6.2 and 8 in main part; section 1 in Annex 
3 

Table 39: Impacts in terms of SME’s competitiveness 

2.  Synthetic assessment  

Compliance  cost  impacts  implied  by  the  preferred  option  are  overall  moderate,  since  the 
requirement  to  be  compatible  with  USB  and  USB-PD  protocols  imply  technical  product 
changes as regards the end product. These additional product design and manufacturing costs 
will  be  by  far  over-compensated  by  the  savings  in  case  of  unbundling  EPS  and  product.  In 
that  sense  the  preferred  option  will  enhance  the  competitiveness  of  those  companies 
embracing  the  concept  of  unbundling,  assuming  that  consumers  and  purchasers  at  large 
choose unbundled devices for convenience and cost benefits. The example of unbundling in 
the mobile phone industry shows that this product strategy does not lead to declining product 

137 

 
 
 
 
 
sales.  For  those  companies  not  following  an  unbundling  strategy  for  reasons  of  a  different 
product strategy or due to concerns that users might use a low-quality EPS with their devices, 
leading  potentially  to  loss  of  brand  reputation,  the  measures  will  lead  to  higher  costs  and 
prices.  Administrative  cost  impacts  implied  by  the  preferred  option  are  overall  low  to 
negligible. For EPS manufacturers a further consolidation of the market can be expected, with 
putting  large  EPS  manufacturers  in  a  better  position  due  to  effects  of  scale.  The  EPS 
manufacturing  industry  is  however  largely  located  outside  the  EU  and  there  are  no  known 
European  manufacturing  SMEs  in  the  market  for  those  products  in  scope  of  this  initiative. 
Time wise, the cost impact is expected to be relatively higher when the regulation first enters 
into force and to diminish afterwards, because initially the entire existing stock of end devices 
not yet compatible with USB or USB-PD has to be redesigned, whereas later this applies only 
to  new  models.  EPS  costs  will  increase  due  to  the  implementation  of  USB  and  USB-PD, 
measures  to  increase  average  active  energy  efficiency,  efficiency  in  low-load  and  to  reduce 
no-load  losses,  compliance  with  a  broader  spectrum  of  specifications  (i.e.  surge  protection) 
and to enhance the reliability of the EPS by design changes and/or use of components with a 
better reliability. Data on bill-of-materials costs for USB EPS however indicates that there is 
currently not a major cost difference, and any such cost difference is likely to diminish with 
further  large  scale  production  of  USB  power  supplies  and  effects  of  scale.  Further,  the 
mandatory  interoperability  requirement  leads  to  more  competition  on  the  EPS  market  and 
positive price effects for consumers: For replacement purchases they can then choose between 
different  power  supply  providers  instead  of  having  to  rely  on  often  overpriced  proprietary 
power supplies. [rating: between - and +]   

The capacity of EU firms to innovate is expected to be strengthened by policies that require 
higher energy efficiency for EPS as some leading semiconductor manufacturers from the EU 
are particularly strong in the field of novel semiconductor materials for power electronics and 
their  market  position  is  expected  to  be  strengthened  through  such  an  initiative,  and  their 
innovation activities in this field are likely to be rewarded by the market, even if the overall 
EPS market declines as expected under this initiative.  

An  example  is  the  proposed  limit  on  efficiency  at  10%  load  that  provides  an  innovation 
opportunity that EU based companies could exploit. An example of innovation in this field is 
a small company based in Europe, PULSIV, that offers an innovative approach65 to reducing 
losses at 10% load that is claimed to be cheaper than existing technology. 

No  impact  on  innovation  in  end-use  products  is  anticipated.  If  necessary  these  can  still  be 
powered by non-USB-C sources. 

[rating: +] 

The  competitive  position  of  EU  firms  with  respect  to  non-EU  competitors  (‘level  playing 
field’)  is  not  negatively  affected  by  the  proposed  measures.  Namely,  they  do  not  affect  EU 
manufacturers’ relative prices and market shares because non-EU competitors face the exact 
same  requirements.  There  are  also  no  suitable  cheaper  substitutes  outside  the  scope  of  the 
imitative. All producers – EU and non-EU – would face some moderate additional costs for 
the end devices from the regulation. These additional costs are expected to be low compared 
to typical price fluctuations (e.g.. those driven by raw material or energy prices) observed on 
markets for EPS powered electronics products, and not significantly different for firms inside 
or outside the EU. The alignment with regulatory requirements in the US further contributes 

65 https://pulsiv.co.uk/pulsiv-osmium-microcontrollers/  

138 

 
 
 
to creating a ‘level playing field’ globally and reduces administrative burden for companies. if 
requirements in the EU and the US are synchronized.  [rating: 0] 

SMEs  producing  products  with  EPS  in  scope  of  this  initiative  will  benefit  from  the 
interoperability of EPS as the one-off costs for EPS for smaller product batches are more of a 
cost issue than for mass market products sold in huge numbers. SMEs with products sold in 
smaller  numbers  therefore  benefit  from  the  fact  that  they  can  rely  on  the  existence  of 
interoperable EPS in households across the EU. There are no known European manufacturing 
SMEs of EPS in scope of this initiative.  [rating: +] 

139 

 
 
 
 
 
ANNEX 10: LIST OF MEASURES AND PRELIMINARY ASSESSMENT 

During the review process, an extensive list of measures has been identified. This was through  
a  supporting  contract,  meetings  with  stakeholders,  interviews,  a  Call  for  Evidence  and 
extensive  desk  research  as  well  as  a  consultation  forum  meeting.  Some  of  the  identified 
measures  have  been  discarded  as  outlined  in  Annex  11.  The  remaining  set  of  possible 
measures for inclusion in policy options are outlined below. 

1.  Scope extension/removal of Annex I (M1) 

1.1. Motivation 

Extending the scope of the Regulation is specifically requested to be considered in points R2 
R3  and  R4  of  the  review  clause.  It  is  also  relevant  to  the  problem  drivers  D1  (too  narrow 
scope),  D2  (untapped  efficiency  potential),  D4  (lacking  interoperability),  D9  (wireless 
charging and power over ethernet). 

1.2. Considerations 

EPS  outside  the  scope  of  the  Regulation  are  not  subject  to  the  current  energy  efficiency 
requirements  and  if  the  Regulation  is  amended,  they  will  not  be  subject  to  the  new  set  of 
ecodesign requirements that the amended Regulation would contain.  

The current Regulation defines its scope through a positive list of products that are powered 
by EPS subject to its requirements. Moving to a comprehensive (open) scope with a negative 
list of defined exemptions would reduce the likelihood of relevant products to be considered 
outside the scope of the Regulation either because of a lack of clarity or deliberate avoidance. 
In particular, the introduction of interoperability requirements would mean that the scope of 
the Regulation would have to be extended to cover standalone USB EPS.  

Energy efficiency requirements would apply also to active PoE injectors. Online data indicate 
that  such  devices  are  capable  to  meet  the  regulated  efficiency  requirements  and  they  are 
already in the scope of the DoE rules. 

At the same time there are changes in the market, resulting in a growing number of devices 
with rechargeable batteries among household appliances, power tools, gardening tools, small 
gadgets,  and  mobility  solutions.  There  are  however  various  reasons  explained  in  Annex  11 
why some of these cannot be brought under the scope of energy efficiency or interoperability 
requirements. 

A significant share of table-top (i.e. not wall-plugged) battery charger models for single cell 
(e.g. AA, AAA) rechargeable batteries are already marketed unbundled from their USB power 
supply.  Because  they  are  not  an  EPS  per  se,  this  product  group  would  need  to  be  brought 
explicitly under the scope of the Regulation to generalise  their interoperability (M5 - power 
supply externalisation). 

While wireless charging harmonisation and active efficiency requirements are discussed and 
discarded in  Annex 11,  wireless  chargers would,  need to  be brought  under the scope of the 
Regulation to allow for interoperability requirements (M5 - power supply externalisation) and 
the limitation of their stand-by power consumption (M4d).  

140 

 
 
 
 
1.3. Stakeholder views 

APPLiA 

ECOS  

Industry 
representatives 

generally  support  including  wireless  charging  while  noting 
technical constraints. 

expressed their general support for extending the scope. 

raised  some  issues  in  relation  to  the  ecodesign  requirements 
that might then be applied e.g. efficiency requirements at 10% 
load and interoperability. 

raised  issues  regarding  the  scope  extension  to  new  products 
(see Annex 11). 

1.4. Final measure 

As a result of the reflections, it is considered desirable to bring a wider range of EPS, wireless 
chargers  and  single-cell  table-top  battery  chargers,  into  the  scope.  This  is  particularly 
important  in  the light  of the potential increase in  interoperability that would  flow from  M3. 
Different  legal  mechanisms  could  be  envisaged  to  achieve  this.  One  approach  could  be 
removal of Annex I and listing only any types of EPS that would be excluded. Alternatively, 
the list of EPS could be modified to become more generic and cover standalone EPS, or the 
list could simply be retained and extended.  

1.5. Description of the measure for inclusion in Policy Options 

M1: Extension of the scope to wireless chargers, single-cell table-top battery chargers, active 
PoE injectors and standalone interoperable EPS. Discarding Annex I. 

2.  Increasing interoperability through requiring compatibility with USB-PD 

specifications and information requirements (M2) 

2.1. Motivation 

This  measure is  intended to  respond to point R5 (options  of interoperability).  It  responds  to 
D4 (EPS lacking interoperability) and in part also to D5 (lack of information on compatibility 
with the load), D6 (bundling EPS with products), D8 (requirements from other legislation and 
standards), and D9 (wireless charging and power over ethernet). 

2.2. Considerations 

An important co-benefit of increasing EPS interoperability is greater consumer convenience. 
Interoperability would make it more feasible for consumers to charge most portable products 
in other locations without also necessarily having to take the EPS for that product with them. 
It  also  enables  products  to  continue  being  used  even  if  there  is  an  EPS  failure  since  other 
equivalent  EPS  can  also  be  used.  Interoperable  EPS  can  be  re-used  for  other  products  for 
other generations of the  same product. While  avoided EPS purchases  can be quantified, the 
benefits  for  consumers  of  being  able  to  use  an  EPS  to  hand  rather  than  find  a  specific  one 
suitable for their device can be significant but are very difficult to assess. 

141 

 
 
  
 
To enable the interoperability of EPS it is necessary to harmonise the connectors to be used, 
the  voltage(s)  and  the  communication  protocol  between  the  power  source  and  the  powered 
product. USB / USB-PD is at present the only standardised power supply protocol available 
and  has  been  mandated  for  the  products  under  the  RED  scope.  While  EPS  are  not  directly 
under this scope, those powering RED devices are indirectly subject to USB requirements.  

The EPS Ecodesign Regulation can foresee the following complementary actions:  

•  Scale-up the benefits of interoperability under RED by extending the scope of “common 

chargers” to power equipment other than the RED devices. 
• 
Inform consumers by marking the “common chargers” with a corresponding logo. 
•  Prevent proprietary chargers from being sold with RED or other USB end-devices. 

The measure would therefore entail the following requirements: 

•  A generic obligation for EPS with a rated power less or equal to 240W to be USB / USB-

PD compliant.  

•  At least one standardised USB Type-C receptacle and no captive cables at the EPS side, 

which in turn requires detachable cables. 

•  No  requirements  regarding  any  additional  USB-A  or  other  ports.  This  would  also  allow 

the implementation of other protocols or electrical parameters on the USB-A port. 

•  Higher  electromagnetic  immunity  and  surge  protection  commonly  required  for  example 
by telecom operators under the standard EN 55035 and the ITU-T K.21 recommendations. 
•  Obligation  for  USB  EPS  to  attempt  restoring  operation  after  fault  conditions.  This 

implementation is generalised while it is an optional feature of the USB standard. 
Information requirements: 

• 

-  A newly designed specific EU “Common Charger” logo (Figure 56), indicating the 
maximum  power  and  the  USB-PD  compatibility,  on  the  nameplate  and  the 
package of USB EPS. This would be complemented by an equivalent logo on the 
“label” required for RED devices66 (Figure 57) which provides the charging power 
range. Apart from that the logo itself would be the same as the one envisaged on 
the EPS side (). 

-  Port marking next to each USB Type-C output, in line with the USB-IF guidelines 

(Figure 58).   

-  A minimum  contrast  ratio for the information printed on the nameplate and EPS 

enclosure. 

66 The Commission has to this end an empowerment under RED to amend the existing logo accordingly. 

142 

 
 
 
 
 
Figure 56 - Common Charger logo – initial design 

Figure 57 - Common Charger "label" for RED devices - initial design 

Figure 58 - USB port marking (from USB-IF guidelines) 

As discussed in Section 2.2.8, Annex 11 and Annex 17, several product types which may be 
powered by EPS cannot fulfil for different reasons interoperability requirements. Exemptions 
from these requirements are therefore proposed for EPS powering: 

•  products  intended for wet-use, like toothbrushes, shavers, certain  kitchen tools, outdoor 

appliances, requiring a specific liquid ingress protection (IPx); 

143 

 
 
 
 
 
 
  
 
 
 
toys; 

•  products requiring a high degree of antistatic protection, like vacuum cleaners; 
•  single-cell battery chargers with pins for direct insertion into socket outlets; 
• 
•  non battery-powered audio products; 
•  cordless phone base-stations with analogue line connection; 
•  products requiring a peak power higher than the USB-PD limits; 
•  products  requiring  technically  justified  high-voltage/low-power  combinations  falling 

outside the USB-PD range. 

The discrete USB-PD voltage levels 5V and 9V may require an adaptation of the input power 
stage  of  certain  appliances.  This  is  however  not  required  above  9V  /  27W  due  to  the 
mandatory AVS feature of the USB standard which allows setting any output voltage level in 
100mV steps. 

The following sub-options cover different subsets of the EPS in scope. 

•  M2a: USB / USB-PD for the EPS powering all products in the current scope of the RED. 

Information requirements. 

•  M2b: USB / USB-PD for the EPS powering all products in the proposed broader scope of 
this  regulation,  excluding  wet-use,  high  ESD,  audio,  and  toy  applications  plus  peak 
power uses and technically justified exceptions . Information requirements. 

The EPS used in particular by the following products remain in the scope of M2b and M2c. 

IT and network equipment, like for example routers, modems, switches, hubs. 

• 
•  Consumer  and  office  electronics,  like  for  example  computer  monitors,  small  TVs, 

compact desktop PCs, set-top-boxes,  printers, game consoles. 
•  Single-cell table-top battery chargers, wireless charging pads.   
•  Charging cradles and docking stations for non-exempted equipment. 

2.3. Stakeholder views 

Industry stakeholders 

APPLiA 

raised concerns regarding the suitability of the USB protocol as a 
common  approach.  In  particular  they  argue  that  it  may  be 
inappropriate for devices working in wet environment and there 
may be a mismatch of technical requirements. 

Regarding appliances that are used in (potentially) wet conditions, the 
EN  60335-1  harmonized  standard  based  on  the  LVD  stipulate  that 
class III construction household appliances like, for example, shavers, 
tooth brushes, or epilators are sold with and used with safety extra low 
voltage  wet use  power  supplies  with  power  output  of  less than  15W. 
This is to ensure consumer safety in wet environment conditions, and 
manufacturers  additionally  use  specific  geometrical  design  of  the 
device  connectors  for  such  wet  conditions  which  they  consider  best 
practice.  These  specific  geometries  are  not  required  in  an  EN  60335 
substandard, nor in any other normative requirement on which industry 
agreed to comply with wet use condition requirements. APPLiA states 
that each manufacturer designs its own proprietary geometry solution 

144 

 
 
 
 
 
 
to prevent that non-IPX4 power supplies are used.  

APPLiA and CECAPI   

consider USB-C unsuitable for damp or wet environments based upon 
internal  research  where  the  connector  spacings  are  considered 
insufficient in the presence of moisture.  

USB-IF 

APPLiA 

Digital Europe 

stated that USB-PD was developed for products used in clean and dry 
environments, and that have fairly constant power demand. 

indicated that USB-PD is not suitable for vacuum cleaners due to the 
very  high  electrostatic  discharge  and  pointed  at  the  standard  which 
must be met by their EPS. 

considers  USB-PD  not  suitable  for  IT  and  consumer  electronics 
equipment,  claiming  among  other  things  that  it  cannot  satisfy  peak-
power  requirements,  and  cannot  react  properly  to  voltage  dips  and 
faults like over-current, over-voltage or over-temperature. 

ZVEI  

pointed  out  that  toys  are  subject  to  very  specific  safety  requirements 
which cannot be met by generic USB-PD supplies. 

APPLiA,  EPTA,  EGMF 
and Digital Europe 

ECOS 

concerned  about  the  additional  costs  of  the  “externalisation”  of  the 
power supply for battery chargers and tools in general. They indicated 
in particular the need for an additional voltage converter, which would 
also reduce the overall efficiency. In addition they indicated that USB 
requirements should not apply to products intended ended to operate in 
inaccessible  locations,  and  battery  chargers  with  pins  for  direct 
insertion into socket outlets. 

proposed that information requirements should be extended to further 
elements  such  as  maximum  current  for  the  cable  or  specific  fast 
charging  protocols  supported  by  EPS.  They  state  that  requirements 
should  be  aligned  with  other  industry  ones.  It  would  be  intended  to 
provide greater information to consumers as to the interoperability of 
EPS. 

USB-IF, 
STMicroelectronics  

Explained  the  difference  between  PPS  and  AVS,  and  indicated  that 
PPS is an expensive feature which is used less frequently. 

Apple 

Explained potential peak-power issues which might be experienced by 
non battery powered products with an audio output. 

Gigaset, Telecom Italia 

Explained  that  cordless  phone  base-stations  with  analogue  line 
connections would be exposed to safety and call quality risks if USB 
powered, unless fitted with a relative costly component.  

M2a offers the minimum level of interoperability to parallel the requirements set in the RED 
for  powered  products  from  the  side  of  EPS.  However,  it  will  bring  very  marginal  benefits, 
primarily due to the information requirements that will make it easier for consumers to ensure 
they use appropriate interoperable EPS. 

M2b  expands  the  interoperability  requirements  to  the  maximum  feasible  while  excluding 
products for which there are justified technical or safety considerations. 

145 

 
 
 
 
2.4. Effect of implementation and choice of measure 

Table 40 below illustrates that in 2035 M2a has a marginal impact on all indicators compared 
to BAU. In contrast M2b leads to improvements in half the parameters.  

Table 40- Estimated impacts of M2 in 2035 

For  M2b,  while  purchase  costs  decrease  slightly  due  to  lower  EPS  purchases  through  their 
reuse, electricity costs are substantially greater due to higher losses in cables and connectors 
and as a result overall consumer expenditure increases. Substantially more energy is required 
overall  as  a  consequence  of  the  higher  electricity  use  and  therefore  more  fuel  is  also 
combusted.  GHG,  acidification  and  PM  emissions  all  decrease  because  of  the  fewer  EPS 
purchased and therefore manufactured.  

In view of this limited impact of M2a it does not merit inclusion in POs and therefore M2b is 
chosen to be further tested. 

2.5. Description of the measure for inclusion in Policy Options 

M2b:  Interoperability  and  information  requirements  for  all  EPS  in  scope,  excluding  those 
powering products for which there are justified technical or safety considerations. 

3.  Minimum energy efficiency at 10% load (M3) 

3.1. Motivation 

This measure responds to point R1 (feasibility of setting efficiency requirements at 10% load) 
of the review article and addresses D3 (EPS less efficient at 10% load). 

3.2. Considerations 

Current active efficiency requirements are set for loads of 25%, 50%, 75% and 100% of the 
EPS maximum output power. The efficiency of all EPS drops rapidly below 25% load and the 
efficiencies at 10% load shown in the evaluation are mainly within the range of 10%pt below 
the  active  efficiency.  The  reported  figures  show  a  substantial  spread.  In  view  of  this,  the 
measure would involve establishing requirements for the minimum energy efficiency of EPS 
at 10% of the maximum rated power.  

Based  on  the  data  in  the  evaluation  a  minimum  stringency  of  10%pt  below  the  regulated 
average  active  efficiency  could  be  considered  since  the  majority  of  the  market  already 
achieves this. This would effectively prevent any backsliding that might occur if higher active 

146 

 EU27 annual impact  Measure 79357666571119550.8283.2234.862.723.820.8779357666571119550.8283.2234.862.723.820.8780557800570021000.7887.6030.852.913.390.78BAUElectricity cost in total consumer expenditure (€m)Particulate Matter (PM, dust) (kt)Greenhouse Gases         (Mt CO2eq.)Gross Energy Requirement (PJ)Absolute new EPS weight  (EoL e-waste) (kt)Fuel combusted (Mt)Acidification emissions          (kt SO2eq.)M2aM2bSocietal Life Cycle Costs                         (€m)Total consumer expenditure                         (€m)Purchase price in total consumer expenditure (€m) 
 
 
 
efficiency  requirements  are  set  and  is  M3a.  A  more  ambitious  requirement  is  to  set  the 
minimum requirement at 5%pt below the currently regulated average active efficiency. This 
level  of  stringency  would  have  the  effect  of  obliging  a  certain  proportion  of  the  market  to 
improve the efficiency at 10% load. The position of these two levels of ambition compared to 
manufacturer  reported  efficiency  figures  is  shown  in  Figure  59.  This  PO  includes 
requirements for interoperability and relevant information. It increases active efficiency by a 
level  of  stringency  met  by  50%  of  current  products,  introduces  wireless  charging  standby 
limits  and  requires  externalisation  of  power  supplies  for  single-cell  battery  charging 
applications. Durability requirements are introduced. 

Figure 59 - Manufacturer reported EPS efficiency data with M3a and M3b thresholds (Fraunhofer IZM) 

Stakeholder comments pointed out that for EPS with a low maximum power, no-load losses 
become a significant share of the total losses at 10% load as shown in Figure 60. Because of 
this, it is impossible for these EPS to respect  a strict requirement on their overall efficiency 
relative to the average active efficiency.  

147 

 
 
 
Figure 60 - Impact of no-load consumption on efficiency at 10% load 

To address this constraint, a further possibility is to apply the requirement only to EPS with a 
10W or greater rated power output as low load operation is mainly of relevance for these EPS. 
M3b  is  therefore  to  set  only  for  EPS  with  an  output  power  of  10W  and  above,  a  minimum 
requirement at 5%pt below the regulated average active efficiency which largely corresponds 
to 6%pt below the revised average active efficiency considered under M4a.  

Figure 61 shows the efficiency at 10% load declared for USB PD EPS at their lowest voltage 
(i.e. 5V) against the proposed M4a limits, for 57 single output and 14 multiple output EPS. In 
line  with  the  clarified  test  method,  the  single  output  EPS  are  considered  against  the  “low 
voltage  limit”,  and  the multiple  output  EPS  against  the  “multiple  voltage  output”  limit,  and 
show a high degree of compliance.   

Figure 61 - Efficiency at 10% load of USB PD EPS (lowest voltage, 5V) 

Data for the 10% load efficiency at the highest USB-PD voltage is scarce, partly due to the 
lack  of  clarity  of  the  requirement  and  test  method.  It  appears  however  that  the  same 
requirement  of  6%pt  below  the  revised  average  active  efficiency  under  M4a  could  be  more 
difficult to meet at that operating point and may deserve a specific consideration. 

3.3. Stakeholder views 

APPLiA 

Raised  concerns  over  the  relevance  of  setting  requirements  for 
low  load  arguing  that  they  do  not  consider  it  to  represent  a 
significant  part  of  EPS  operation.  Provided  data  supporting  the 
exclusion of lower power EPS. 

148 

 
 
 
 
Digital Europe 

Raised  concerns  regarding  USB  PD  EPS  in  general,  and  those 
with an output power above 100W in particular. 

Based  on  the  analysis  and  stakeholder  comments  two  possible  levels  of  stringency  of  the 
measure were assessed. These are: 

M3a: setting a threshold for efficiency at 10% of maximum load at 10%pt below the average 
active efficiency. 

M3b:  setting  a  threshold  for  efficiency  at  10%  of  maximum  load  at  6%pt  below  the  full-
power average active efficiency only for EPS with an output power of 10W and above. 

3.4. Effect of implementation and choice of measure 

The table below illustrates the expected impact  of each of the stringencies  of the  efficiency 
requirement at 10% load in 2035: 

Table 41 - Estimated impact of M3 in 2035 

The assessment shows that M3a has negligible impact. It would provide an assurance against 
a deterioration of efficiency at  10% load but  no  improvement. M3b has  benefits  and merits 
assessment in policy options even though on a standalone basis it leads to a slight increase in 
consumer costs. 

3.5. Description of the measure for inclusion in Policy Options 

M3b: For EPS with an output power of 10W and above the efficiency at 10% of the maximum 
load must be not more than 6%pt below the regulated full power average active efficiency 

4.  Raising the minimum requirement on active average efficiency and limiting stand-by 

losses for wireless chargers (M4) 

4.1. Motivation 

Increasing the active efficiency requirements was not explicitly identified in the review article 
of the Regulation. However, the review article does request for it to be reviewed in the light of 
technical progress and the evaluation has identified that there has been technical progress and 
that a significant share of EPS on the market have efficiencies higher than the minima set in 

149 

 
 
 
 
 
 
the Regulation. The measure addresses D2 (untapped potential for higher efficiency) and D9 
(wireless charging). 

4.2. Considerations 

Data gathered as part of the evaluation indicates the possibility for more stringent active and 
no-load efficiency requirements for EPS. The measure would involve more ambitious average 
active efficiency requirements, raising the threshold across a broad range of maximum power 
output by approximately 1%pt  in  M4a, a more ambitious 2 - 3%pt  in  M4b and  3 - 4%pt  in 
M4c. 

The analysis of the EPS database in the evaluation has shown that the assumptions in the US 
about the impact of the stringency increases are broadly equivalent for the EU market. This is 
illustrated in Figure 62 

Figure 62- Active average efficiency in EU database (left) and DoE analysis (right) 

A need for clarification of the application and testing of requirements and has been observed, 
in  particular  for  adaptive  power  supplies,  also  in  light  of  the  recently  updated  DoE  rule  10 
CFR 43067. The following clarifications are therefore considered necessary for adaptive and in 
particular USB-PD power supplies. They are all included in M4a, M4b and M4c: 

•  Application  of  the  single  voltage,  low  voltage,  and  multiple  voltage  output  efficiency 

limits and the corresponding testing. 

•  Application of any 10% load limits and the corresponding testing. 
•  The no-load testing. 
•  Specification of a standardised USB cable for testing. 
•  Testing  of  USB  power  supplies  embedded  in  other  products,  and  of  products  fulfilling 

also other functions.  

Losses in the output cables are assessed using the baseline assumptions about power profiles, 
assuming the majority will be powered from USB outlets with an additional assumption about 
the  average  voltage  used  for  each  profile.  The  USB  protocol  specifies  the  maximum 
resistance of the cables that may be used as 0.25Ω for 3A and 0.15Ω for 5A. Based upon the 
assumed load profiles and durations of use for each class of EPS the total energy losses due to 
the use of power cables  meeting the USB protocol  requirements amount  to  around 2.9PJ in 

67www.federalregister.gov/documents/2022/08/19/2022-15975/energy-conservation-program-test-procedure-for-
external-power-supplies 

150 

 
 
 
 
the period covered by the Impact Assessment.  These losses are around 3.6% of the total GER 
related to EPS.  

Actual cable resistances in the market measured on a sample of 115 cables show that: 

•  8% exceed the overall USB resistance specification - by 0.112Ω on average; 
•  37% exceed the ground wire resistance specification - by 0.029Ω on average. 

The cables where the ground wire resistance exceeds the specification are included in those 
exceeding the overall resistance.  

On the assumption that this sample is representative of the overall market, it is calculated that 
the cable resistance would be 0.01Ω higher on average across the whole stock than the USB 
requirements.  Using  the  same  assumed  load  profiles  and  durations  of  use  for  each  class  of 
EPS,  the  total  savings  that  can  be  achieved  by  avoiding  this  excess  resistance  amount  to 
around  0.12PJ  in  the  period  covered  by  the  Impact  Assessment. These  losses  are  between 
2.6% and 26% of the savings achievable from the different levels of active efficiency assessed 
but independent of them. 

The electromagnetic coupling efficiency of a wireless charging pad varies significantly with 
the  position  of  the  product  on  the  pad  and  its  distance  to  it.  It  is  therefore  considered 
impossible to date to set requirements for the coupling efficiency. This has been confirmed by 
recent work on EPS and battery charging efficiency by the US DoE. An outcome of the same 
work has been however the proposal for a stand-by limit of 0.8W for open placement wireless 
chargers. Assuming a (low-voltage) EPS low-load efficiency of 60% this would translate into 
a stand-by limit of 0.48W for the wireless charging pad. Fixed-location wireless chargers have 
been excluded from this limit in the DoE proposal, most probably because they are subject to 
battery-charging rules. There is however no technical reason observed why the fixed-location 
wireless charging pad should not be able to meet the same stand-by limit. 

4.3. Stakeholder views 

Industrial stakeholders 

did  not  question  new  efficiency  limits  in  line  with  those 
proposed by the DoE 

ANEC/BEUC and ECOS 

requested stricter limits. 

4.4. Effect of implementation and choice of measure 

Table 42 illustrates the expected impact  of each  of the stringencies for the active efficiency 
measure and separately the impact of the wireless charging pad standby limit in 2035: 

151 

 
 
 
Table 42 - Estimated impact of M4 in 2035 

M4a to M4c are alternatives. The results clearly show that as the stringency increases from a) 
to c) purchase costs increase while electricity costs decrease. Of these, only M4a on its own 
has energy savings sufficient to offset the additional purchase costs and therefore leads to  a 
reduction in overall consumer expenditure. 

M4d  is  independent  of  M4a  to  M4c  since  it  purely  addresses  the  standby  consumption  of 
wireless  charging  pads  that  are  not  covered  by  the  other  sub-measures.  This  sub-measure 
leads to a significant reduction in electricity and overall consumer expenditure. 

4.5. Description of the measure for inclusion in Policy Options 

M4a: Active average efficiency and no-load requirements set at a level corresponding to the 
draft  DoE  level  VII  of  the  most  recent  proposal  by  the  US  Department  of  Energy. 
Clarification that adaptive EPS to be tested and required to meet minimum requirements at 
lowest and highest voltage levels. 

M4b: Active average efficiency increased to a level achieved by 50% of the current market, 
and  no-load  requirements  reduced  to  a  level  corresponding  to  the  draft  DoE  level  VII. 
Clarification that adaptive EPS to be tested and required to meet minimum requirements at 
lowest and highest voltage levels. 

M4c: Active average efficiency increased to a level achieved by best performing EPS in the 
current market, and no-load requirements reduced to a level corresponding to the draft DoE 
level  VII.  Clarification  that  adaptive  EPS  to  be  tested  and  required  to  meet  minimum 
requirements at lowest and highest voltage levels. 

M4d: Open placement or fixed location wireless charging pads (without EPS) to be subject to 
a standby power limit of 0.48W. 

5.  Externalisation of power supply circuitries for single-cell battery charging devices 

and wireless chargers (M5) 

5.1. Motivation 

This measure is in response to points R2 (bringing wireless chargers in scope), R3 (bringing 
power over ethernet injectors in scope) and R4 (bringing EPS for equipment outside Annex I  

152 

 EU27 annual impact  Measure 79357666571119550.8283.2234.862.723.820.869379257656571319430.8182.7734.862.713.820.869279547685577019160.8181.7734.862.673.820.869180367770593818320.8078.6634.862.563.810.868777957530572418050.8077.6734.862.523.800.8685M4dBAUM4aM4bM4cAbsolute new EPS weight  (EoL e-waste) (kt)Fuel combusted (Mt)Acidification emissions          (kt SO2eq.)Particulate Matter (PM, dust) (kt)Societal Life Cycle Costs                         (€m)Total consumer expenditure                         (€m)Purchase price in total consumer expenditure (€m)Electricity cost in total consumer expenditure (€m)Greenhouse Gases         (Mt CO2eq.)Gross Energy Requirement (PJ) 
 
 
 
in  scope)  of  the  review  article.  It  addresses  D4  (interoperability  of  EPS)  and  D9  (wireless 
charging and power over ethernet), and is linked to M1. 

5.2. Considerations 

Single-cell table-top battery chargers and wireless charging devices are brought into the scope 
of  the  Regulation  (M1)  with  the  purpose  to  require  by  design  a  separation  of  the 
battery/wireless  charging  functionality  from  the  power  supply  function.  The  power  supply 
unit would be required to be USB / USB-PD compatible and would comply with efficiency 
and no-load requirements and potentially other requirements introduced with any of the other 
measures. 

It is important that products intended to be used in a wet environment are exempted from this 
requirement to avoid any safety problems or difficulties with the connectors used. 

5.3. Stakeholder views 

APPLiA,  EPTA,  EGMF 
and Digital Europe 

EPBA 

EPTA 

requested to restrict this requirement to battery chargers already 
using  an  EPS,  warning  about  an  increased  system  cost  and 
impact on energy efficiency mainly due to an additional voltage 
converter inside the charger.  

requested  not  to  apply  such  a  requirement  to  battery  chargers 
with pins for direct insertion into socket outlets. 

argued  not  to  apply  such  a  requirement  to  battery  chargers  for 
battery packs for power and gardening tools. 

5.4. Effect of implementation and choice of measure 

The table below illustrates the expected impact of this measure in 2035: 

Table 43 - Estimated impact of M5 in 2035 

5.5. Description of the measure for inclusion in Policy Options  

M5:  Externalisation  of  the  power  supply  unit  of  wireless  chargers  and  single-cell  battery 
chargers with the exception of products to be used in a wet environment. 

6.  Durability (M6) 

6.1. Motivation 

153 

 EU27 annual impact  Measure 79357666571119550.8283.2234.862.723.820.8779277658570419550.8183.1734.782.723.810.86Absolute new EPS weight  (EoL e-waste) (kt)Fuel combusted (Mt)Acidification emissions          (kt SO2eq.)Particulate Matter (PM, dust) (kt)BAUGreenhouse Gases         (Mt CO2eq.)Gross Energy Requirement (PJ)M5Societal Life Cycle Costs                         (€m)Total consumer expenditure                         (€m)Purchase price in total consumer expenditure (€m)Electricity cost in total consumer expenditure (€m) 
 
 
 
Interoperable EPS are intended to  be used longer than conventional  device-specific external 
power supplies. The intention is that they would no longer be discarded at the end-of-life of 
the  powered  end-device,  but  rather  reused  with  a  replacement  or  a  different  device.  It  is 
therefore essential that interoperable external power supplies do not fail for reasons which can 
be avoided with relatively simple design measures. 

This  measure  is  partly  in  response  to  point  R5  (options  for  interoperability)  of  the  review 
clause and addresses D4 (lacking interoperability of EPS). 

6.2. Considerations 

The  measure  would  introduce  lifetime  requirements  for  the  electronic  components  of  USB 
EPS.  The  aim  is  to  limit  the  share  of  EPS  that  would  otherwise  need  to  be  replaced  due  to 
technical defects of the electronics during the assumed longer life. 

The two distinct metrics normally used to predict the durability and reliability of an electric 
system are lifetime and MTBF (Mean Time Between Failures). The lifetime parameter of an 
EPS reflects its wear-out under normal operating conditions, while the MTBF is a statistical 
measure for abnormal faults and failures. The standard ETSI ES 202 874-1 V1.2.1 for telecom 
power supplies requires  1) a reference lifetime of 10 years continual operation at maximum 
output power, and 2) an MTBF of 300 000h at 40°C operation.  At the same time, requiring 
EPS  to  be  more  efficient  (M4)  means  in  turn  a  lower  heat  dissipation  which  prolongs  the 
lifetime of the device. 

Repair  shop  data68  indicate  that  20-30%  of  the  EPS  handed  in  for  repair  had  stopped 
functioning due to a broken DC cable or other issues related to its connectors and wiring. Due 
to the high number of database entries from several countries, this percentage can in turn also 
be  assumed  as  representative  for  the  entire  population  of  damaged  EPS.  This  failure  is 
normally due to inadequate mechanical and sometimes electrical stress to which this external 
EPS  component  is  often  exposed.  In  particular  the  so  called  “captive”,  i.e.  hard-wired  USB 
cables  are prone to  premature failure at the  mechanical  connection to  the EPS body.  At the 
same  time,  the  electrical  components  are  protected  due  to  their  encapsulation  and  are 
normally still functional. 

Requiring USB cables to  be always  detachable  (a co-benefit of the interoperability measure 
M2a)  would  allow  their  unsophisticated  replacement,  also  by  laymen,  in  case  of  cable 
failures. This is already a trend for wall plugged USB EPS, but usually not implemented for 
table top chargers with an AC cord. 

6.3. Stakeholder views 

ANEC 

ZVEI, PSMA 

initially questioned why measures to address reliability are not 
considered. 

argued  that  the  standards  to  determine  the  MTBF  are  not 
comparable,  and  that  the  wear-out  of  the  power  supply  is 
determined  by  the  lifetime  of  electrolytic  capacitors  which 
depends on many complex design parameters. 

68 https://openrepair.org/open-data/downloads/ 

154 

 
 
 
STMicroelectronics 

considers a captive cable more stable mechanically 

Granite River Labs 

indicated  that  the  USB-IF  certification  which  allows  captive 
cables would deviate from EC compliance rules 

6.4. Effect of implementation and choice of measure 

Table 44 - Estimated impact of M6 in 2035 

This measure will only have an impact if implemented along with M2 since that measure will 
lead to longer EPS lives. It will also only have an impact on products covered by M5 if that 
measure  is  also  implemented.  In  view  of  that  Table  44  shows  the  expected  impact  of  the 
implementation  in  2035  of  M2  with  M5  and  the  impact  of  M2  with  M5  and  M6.  The 
additional  impact  of  M6  alone  when  implemented  in  conjunction  with  M2  and  M5  is  then 
obtained by subtracting the two combined approaches. 

Unsurprisingly, by extending the life of the EPS, the assessment of the standalone measure (in 
conjunction with M2 and M5) shows that it appears attractive from a  consumer expenditure 
perspective while also delivering some modest environmental benefits due to the reduced EPS 
purchases. 

6.5. Description of the measure for inclusion in Policy Options 

M6: Introduction of mandatory ETSI durability standard requirements.  Requiring USB EPS 
to  be  fitted  at  their  output  only  with  receptacles  for  detachable  USB  cables  (covered  under 
M2a).  

155 

 EU27 annual impact  Measure 79357666571119550.8283.2234.862.723.820.8780557800570021000.7887.6030.852.913.390.7879277658570419550.8183.1734.782.723.810.8680467793569321000.7787.5430.772.913.380.7879557710560921010.7687.4330.212.913.330.76-91-83-841.1-0.01-0.11-0.560.000-0.05-0.014Societal Life Cycle Costs (€m)Absolute new EPS weight  (EoL e-waste) (kt)Fuel combusted (Mt)Acidification emissions          (kt SO2eq.)Particulate Matter (PM, dust) (kt)BAUTotal consumer expenditure (€m)Purchase price in total consumer expenditure (€m)Electricity cost in total consumer expenditure (€m)Greenhouse Gases         (Mt CO2eq.)Gross Energy Requirement (PJ)M2bM5M2b+M5+M6M2b+M5M6 impact 
 
 
 
 
 
 
 
 
 
7.  Final measures for assessment in Policy Options 

Name 

Description of the measure 

M1 

M2b 

M3b 

M4a 

M4b 

M4c 

M4d 

M5 

M6 

Extension of the scope to wireless chargers, single-cell table-top battery chargers, active 
PoE injectors and standalone interoperable EPS. Discarding Annex I. 
Interoperability  and  information  requirements  for  all  EPS  in  scope,  excluding  those 
powering products for which there are justified technical or safety considerations. 

For EPS with an output power of 10W and above the efficiency at 10% of the maximum 
load  must  be  not  more  than  6%pt  below  the  regulated  full  power  average  active 
efficiency 

Active average efficiency and no-load requirements set at a level corresponding to the 
draft  DoE  level  VII  of  the  most  recent  proposal  by  the  US  Department  of  Energy. 
Clarification that adaptive EPS to be tested and required to meet minimum requirements 
at lowest and highest voltage levels. 

Active  average  efficiency  increased  to  a  level  achieved  by  50%  of  the  current  market, 
and no-load requirements reduced to a level corresponding to the draft DoE level VII. 
Clarification that adaptive EPS to be tested and required to meet minimum requirements 
at lowest and highest voltage levels. 

Active  average  efficiency  increased  to  a  level  achieved  by  best  performing  EPS  in  the 
current market, and no-load requirements reduced to a level corresponding to the draft 
DoE  level  VII.  Clarification  that  adaptive  EPS  to  be  tested  and  required  to  meet 
minimum requirements at lowest and highest voltage levels. 

Standby  power  limit  of  0.48W  for  open  placement  or  fixed  location  wireless  charging 
pads (without EPS). 

Externalisation  of  the  power  supply  unit  of  wireless  chargers  and  single-cell  battery 
chargers with the exception of products to be used in a wet environment. 

Introduction of mandatory ETSI durability standard  requirements. Requiring USB EPS 
to  be  fitted  at  their  output  only  with  receptacles  for  detachable  USB  cables  (covered 
under M2a). 

156 

 
 
 
 
 
ANNEX 11: DISCARDED MEASURES  

As a result of analysis and consultation with stakeholders a number of options were discarded. 
These are outlined below along with a brief description of the reasons for their rejection. 

1.  Setting requirements for repairability  

For  several  product  groups  under  the  Ecodesign  Framework  reparability  requirements  have 
been  implemented  since  2019.  The  rationale  for  this  is  that  repair  can  lengthen  the  useful 
lifetime  of  the  product  thus  reducing  the  environmental  impacts  from  producing  a 
replacement. These requirements have mostly related to the availability of information and the 
supply of spare parts. Reparability scoring has been required in the regulation on Smartphones 
and Tablets. Work is ongoing on reparability scoring for tumble dryers.  

The  consumer  NGO  ANEC  was  keen  for  repairability  options  to  be  considered  during  the 
EPS review. 

Where  spare  parts  have  been  made  available  for  other  Ecodesign  products  a  distinction  has 
been made between those for which it is safe to consumers to carry out the repair themselves 
and  those  for  which  this  is  dangerous  and  so  the  spare  parts  should  only  be  available  to 
professional repairers and the repair be carried out by them. 

In the case of EPS, a major concern would be that opening the power supply provides direct 
access to the 230V circuitry. This would raise major safety concerns. In view of these, repair 
could theoretically be carried out by professionals, but under no circumstances should repair 
by  consumers  be  facilitated.  However,  in  view  of  the  rather  low  cost  of  EPS,  repair  by 
professionals is not economically viable and is therefore not expected to happen, even if the 
procedures for access were simplified and necessary spare parts made available.  

In  view  of  these  considerations  this  measure  was  discarded  on  the  grounds  of  safety  and 
economic viability. 

2.  Wireless charging harmonisation and active efficiency requirements 

The  Ecodesign  regulation  review  clause  required  options  for  the  inclusion  of  wireless 
charging  in  the  scope  of  the  Regulation  to  be  addressed  (R2).  Inclusion  within  the  scope 
would  enable  the  application  of  some  or  all  of  the  ecodesign  requirements  contained  in  the 
Regulation to wireless chargers. The two main types of requirements explored in the review 
are for energy efficiency and interoperability. The NGOs ANEC/BEUC and ECOS strongly 
supported addressing wireless charging efficiency as part of the impact assessment. 

The  energy  efficiency  of  wireless  charging  depends  on  the  various  system  components 
including  the  power  transformation  circuitry,  power  transmission  coil,  power  reception  coil 
and  battery  charging.  The  electrical  and  physical  characteristics  of  the  end-device  play  a 
crucial role. At present there are no reliable, repeatable, representative means to determine the 
efficiency  of  the  power  transmission.  A  fundamental  problem  is  how  to  ensure  a 
representative  alignment  of  the  reception  and  transmission  devices  since  this  has  a  major 
impact  on  overall  efficiency.  In  view  of  this  difficulty,  as  in  other  global  markets  the 
possibility of regulating the active efficiency of wireless charging is discarded. 

157 

 
 
 
Concerning interoperability, this relates to the possibility of wireless devices to be usable with 
all wireless charging pads. If this were feasible it could increase consumer convenience and 
reduce the number of wireless charging pads needed, thus leading to reduced environmental 
impacts.  The  operation  of  wireless  charging  depends  partly  on  the  physical  and  electrical 
aspects  of  the  two  devices,  including  the  frequency  of  operation  and  the  protocol  used 
between them. The market is split between inductive, resonant, RF and other technologies69. 
Both resonant and RF technology are expected to grow and other various benefits.  

In view of this, while some protocols such as Qi currently have a large share of the market, 
and  the  latter  contains  specifications  for  both  inductive  and  resonant  charging  it  is  unclear 
whether  this  will  end  up  dominating  the  market.  In  view  of  these  developments,  it  would 
appear  to  be  premature  to  attempt  to  define  a  unique  approach  and  therefore  regulating  the 
interoperability of wireless charging is discarded. 

3.  Introduction of an EU Energy Label 

An EU Energy Label under Framework Regulation (EU) 2017/1369 as a complement to eco-
design requirements is an option for other product groups. However, there has never been an 
Energy Label introduced for EPS in parallel to the previous ecodesign requirements.  

A key reason for this is that as long as the majority of EPS are provided bundled with an end-
device, an Energy Label on the EPS only or in parallel to the main product Energy Label is 
very  likely  to  create  confusion  to  the  consumer.  While  this  situation  may  change  if 
interoperability requirements are introduced and there is  a widespread voluntary unbundling 
of  EPS  from  end-use  products,  there  are  other  reasons  why  an  energy  label  may  be 
inappropriate. 

Firstly,  given  the  high  level  of  energy  efficiency  requirements  put  in  place  in  the  EPS 
ecodesign requirements, and the resulting limited performance spread in the market, there is 
probably insufficient distinction in performance to justify the introduction of seven efficiency 
classes,  each  with  enough  energy  efficiency  range.  This  range  will  be  further  reduced  if 
stricter active efficiency requirements are implemented. 

Secondly, it is unclear, given the low level of energy losses in the EPS, whether there would 
be  sufficient  motivation  for  consumers  to  pay  attention  to  such  an  energy  label.  It  is 
noteworthy that no stakeholder is explicitly in favour of an EU Energy Label for this product 
category. In view of all these factors the option of introducing an energy label is discarded. 

4.  Voluntary agreement by the industry 

According  to  the  Ecodesign  Framework  Directive,  voluntary  agreements  must  be  given 
priority over legislative actions, provided they meet the objectives in a quicker and more cost-
effective manner. The product is characterised by a very large number of manufacturers, and 
it is likely to be very difficult, if not impossible, for an agreement to be established covering a 
larger enough share of the market.  

The  current  review  is  of  an  existing  ecodesign  Regulation  and  therefore  in  the  past  it  was 
clearly also not possible to establish a voluntary agreement. A further relevant factor is that 

69 https://www.grandviewresearch.com/industry-analysis/wireless-charging-market  

158 

 
 
 
EPS are sold globally and subject to regulation in other jurisdictions at global level and this 
may hamper the ability for the industry to agree a common approach.  

In  view  of  all  these  factors  and  the  fact  that  the  industry  has  not  proposed  any  voluntary 
agreement this option has been discarded. 

5.  Extension of the scope to certain other products  

The current Regulation defines its scope through a positive list of products that are subject to 
its requirements. Moving to a comprehensive scope with defined exemptions could reduce the 
likelihood  of  relevant  products  to  be  considered  outside  the  scope  of  the  Regulation  either 
because of a lack of clarity or deliberate avoidance. In view of this Measure 1 is to remove the 
positive  list  in  annex  I  of  the  Regulation.  However,  various  objections  to  this  blanket 
coverage were raised. 

Power supplies to charge e-bikes represent a significant and growing market. However, the 
Confederation of the European Bicycle Industry (CONEBI) is concerned about extending the 
scope  of  the  EPS  Regulation  to  e-bike  chargers.  They  state  that  safety  features  of  e-bike 
systems are built into the charger and the battery, not the e-bike itself and that therefore the 
charger is more than an EPS. These features include functions to measure the temperature of 
the battery and  adjust the rate of charge or limit  the output voltage to  prevent  overcharging 
even  in  a  malfunction  state.  Failure  to  monitor  charging  and  the  battery  may  pose  a  fire 
hazard.  E-bike  chargers  have  a  higher  safety  focus  due  to  their  operating  environment. 
CONEBI doubt whether significant environmental gains can be achieved if USB EPS are used 
with  e-bikes.  In  view  of  the  stated  dual  function  of  a  bike  charger,  the  only  approach  to 
regulate their efficiency would be as with other types of chargers be to separate the EPS from 
the charger itself. This would either require building the charging part of the device into the e-
bike or two separate external devices.  

Article  1  of  the  Ecodesign  Directive  setting  the  subject  matter  and  scope  states  that  “This 
Directive shall not apply to means of transport for persons or goods”. While the charger for an 
e-bike is not in itself a means of transport, this exclusion has also been understood to apply to 
devices, such as for example motors, used in means of transport. Since a charger for an e-bike 
is  functionally  integrated  with  the  e-bike  due  to  the  integration  of  the  charging  control  and 
battery monitoring circuitry it can be strongly argued that it is specific to a means of transport 
and therefore outside the scope of the Ecodesign Directive and thus implementing measures 
adopted  under  it.  At  the  same  time  electric  vehicle  chargers  have  been  prioritised  as  a  new 
the  Ecodesign  and  Energy  Labelling  Working  Plan  2022-202470.  The 
product  by 
corresponding  ecodesign  regulation  will  fall  under  the  ESPR  and  the  on-going  work71  also 
explores requirements for e-bike chargers. 

CONEBI  have  also  stated  that  chargers  for  e-bikes  are  subject  to  industry  driven 
harmonisation efforts and that this will in any case mean that efforts for interoperability of the 
chargers  would  be  less  relevant.  Such  harmonisation  efforts  are  being  considered  under  the 
mandate stemming from the Batteries Directive. 

Lighting Europe pointed out that power supplies of lighting equipment are already regulated 
as control gear under Regulation (EU) 2019/2020 and therefore it would be double regulation 

70 https://energy.ec.europa.eu/publications/ecodesign-and-energy-labelling-working-plan-2022-2024_en 

71 https://ecodesign-ev-charger.eu/ecodesign/the-study/ 

159 

 
 
 
to  include  them  under  this  Regulation.  In  view  of  this,  power  supply  units  for  lighting 
equipment are excluded from the extension of the scope. 

ZVEI  and  EPSMA  argued  to  maintaining  the  exemption  of  commercial  and  industrial 
power supplies, which otherwise would fall under the scope of the Regulation by abandoning 
Annex I. These power supplies fulfil specific additional functions, are optimised for specific 
operating points and are unlikely to achieve energy savings. For this reason they are excluded 
from the extension of the scope. 

EPTA and EGMF indicated that battery chargers for power and gardening tools are often 
used by professionals in construction environments where they are exposed to humidity, dust, 
dirt and mechanical stress. For this reason a USB-C receptacle replacing the hard wired AC 
cord is considered not sufficiently robust. In addition, it was argued that the few products on 
the  market  with  such  a  feature  have  a  significant  lower  efficiency.  This  product  group  is 
therefore excluded from the extension of the scope. 

6.  Introduction of information requirements on efficiency  

The  majority  of  EPS  are  sold  and  used  globally  rather  than  being  designed  for  a  specific 
regional market. This is illustrated by the wide input voltage range that usually covers 110 to 
250V  AC.  Observation  of  manufacturer  data  supplemented  by  testing  of  a  small  number  of 
EPS  illustrates  that  in  general  EPS  have  a  slightly  higher  efficiency  when  operated  at  EU 
input voltage levels. This means that if an obligatory marking of active energy efficiency of 
EPS based on the testing for EU conditions was introduced this could be misleading. 

There is a risk that such an obligatory marking could even be illegal for other markets which 
would  result  in  EU  efficiency  marked  EPS  becoming  bespoke  devices  purely  for  the  EU 
market. This would lead to higher costs for pure EU EPS and might reduce the potential spill 
over  benefits  from  other  invisible  EU  regulatory  requirements,  such  as  setting  efficiency 
requirements at 10% load, to other global markets. 

In  parallel  with  the  thinking  on  the  energy  label,  it  is  also  unclear,  given  the  low  level  of 
energy losses in the EPS, whether there would be sufficient motivation for consumers to pay 
attention to such an efficiency marking. 

In  view  of  these  doubts  over  the  effect  of  such  a  measure  and  the  potential  incompatibility 
with global markets an efficiency marking measure is discarded. 

7.  Interoperability requirements for certain product categories 

In principle, the maximum environmental benefit and improvements to consumer convenience 
are likely to be achieved through the widest application of interoperability requirements. This 
was the starting point for the deliberations but industry stakeholders raised concerns regarding 
the  suitability  of  the  USB  protocol  as  a  common  approach.  In  particular,  they  argue  that  it 
may be inappropriate for devices working in wet environment and there may be a mismatch of 
technical requirements.  

Regarding appliances that are used in (potentially) wet conditions, APPLiA states that the EN 
60335-1  harmonized  standard  based  on  the  LVD  stipulate  that  class  III  construction 
household appliances like, for example, shavers, tooth brushes, or epilators are sold with and 
used  with  safety  extra  low  voltage  wet  use  power  supplies  with  power  output  of  less  than 
15W.  This  is  to  ensure  consumer  safety  in  wet  environment  conditions,  and  manufacturers 
additionally use specific geometrical design of the device connectors for such wet conditions 

160 

 
 
which they consider best practice. These specific geometries are not required in an EN 60335 
substandard, nor in any other normative requirement on which industry agreed to comply with 
wet  use  condition  requirements.  APPLiA  states  that  each  manufacturer  designs  its  own 
proprietary geometry solution to prevent that non-IPX4 power supplies are used.  

APPLiA and CECAPI  also consider USB-C unsuitable for damp or wet environments based 
upon  internal  research  where  the  connector  spacings  are  considered  insufficient  in  the 
presence of moisture. In addition APPLiA indicated that USB-PD is not suitable for vacuum 
cleaners due to the very high electrostatic discharge and pointed at the standard which must be 
met by their EPS. ZVEI pointed out that toys are subject to very specific safety requirements 
which cannot be met by generic USB-PD supplies. 

USB-IF stated that USB-PD was developed for products used in clean and dry environments, 
and that have fairly  constant power demand. Digital  Europe considers USB-PD not  suitable 
for IT and consumer electronics equipment, claiming among other things that it cannot satisfy 
peak-power  requirements,  and  cannot  react  properly  to  voltage  dips  and  faults  like  over-
current, over-voltage or over-temperature. 

After taking account of input from stakeholders and initial analysis it was concluded that the 
interoperability  requirements  should  not  be  considered  for  toys,  non-battery  powered  audio 
devices, products subject to electrostatic discharge, wet-use, peak power and where there are 
technical reasons for a high voltage low power combination incompatible with the USB-PD 
protocol. Including these products in the interoperability measure is therefore discarded. 

8.  Unbundling EPS from the products they power  

This  measure  would  involve  establishing  requirements  for  selling  products  without  an 
external power supply. This would incentivise reuse or shared use of interoperable EPS with 
other products and thus to purchase less EPS in total. It is considered in response to point R5 
(circular economy and interoperability) of the review article and to address D6 (bundling of 
products). 

Some industry stakeholders have raised barriers to unbundling from other requirements. For 
example, APPLiA state that some current safety standards (e.g. the EN 60335 series) do not 
allow  unbundling.  In  addition  ITI  remark  that  unbundling  could  lead  to  additional  costs 
through  extra  shipping  requirements  and  material  redundancy  though  additional  packaging 
materials. 

Legal  analysis  shows  that  requiring  mandatory  unbundling  is  not  a  feasible  regulatory 
measure as, contrary to the RED, the empowerments in the ecodesign Directive do not allow 
for an unbundling requirement targeting the powered product. Annex I, part 1, point 1 sets out 
the phases of the product lifecycle for which requirements can be set. The supply or sale of 
the  product  is  not  included  in  this  list.  In  view  of  this  unbundling  can  therefore  only  be  a 
voluntary measure. In view of this legal barrier this measure is discarded. 

161 

 
 
 
 
ANNEX 12: SELECTION OF POLLUTANTS FOR ANALYSIS 

1.  Outputs from the ecoreport tool 

The ecoreport tool used to carry out the LCA for this Impact Assessment provides a fixed set 
of outputs as shown below:  

Other resources and waste 

•  Total Energy (GER) 
•  of which, electricity (in primary MJ)  
•  Water (process) 
•  Water (cooling) 
•  Waste, non-haz./ landfill 
•  Waste, hazardous/ incinerated 

Emissions (Air) 

•  Greenhouse Gases in GWP100 
•  Acidification, emissions 
•  Volatile Organic Compounds (VOC) 
•  Persistent Organic Pollutants (POP) 
•  Heavy Metals 
•  PAHs 
•  Particulate Matter (PM, dust) 

Emissions (Water) 

•  Heavy Metals 
•  Eutrophication 

The underlined outputs are those which have been chosen for carrying out the analysis. The 
reasoning for the choice of these emission categories is discussed in this annex. 

The main environmental impacts of EPS in the EU are a result of the electricity consumption 
by  them.  The  environmental  impacts  of  electricity  generation  are  mainly  driven  by  the 
emissions  from  Large  Combustion  Plants  (LCPs).  These  are  regulated  under  the  industrial 
emissions  Directive  in  the  EU  and  their  emissions  monitored.  Information  on  the  scale  of 
pollutant  emissions  from  the  energy  sector,  including  LCPs,  is  provided  in  the  Industrial 
Emissions Portal72. 

2.  Emissions to air 

Emissions  from  industry  represent  a  significant  share  in  total  emissions  of  many  of  these 
pollutants. This was analysed in an earlier study73 which showed at the time that for emissions 
to air, industry represents about 86% of PAH, 73% of SOx, 68% of POPs, 30% of NOx, 22% 
of  NMVOC,  12%  of  PM  and  in  the  order  of  50%  for  many  metals.  These  categories  are 
therefore all relevant. 

72 https://industry.eea.europa.eu/  

73 Contribution of industry to pollutant emissions to air and water; September 2014 

162 

 
 
 
 
The  Industrial  Emissions  Portal  provides  information  on  the  total  emissions  of  these 
pollutants from industry and the share of those for the energy sector. Additionally, an Eionet 
Report74  provides  an  overview  of  the  main  pollutant  emissions  to  air  from  EU  industrial 
facilities  and  their  relative  importance  through  the  application  of  damage  costs  for  these 
emissions. 

Taking these sources together provides the share of the energy sector in industrial emissions 
and the estimated damage costs for these emissions. These are shown in Table 45: 

Emissions to air 

Energy share of 
industry* 

Total industry 
emissions* 

Total value+ 

Emissions included in IA analysis 
CO2 
SOx 
NOx 
PM 

60.8% 
66.8% 
49.3% 
29.3% 

Emissions not included in IA analysis 
NMVOC 
PAH 
Organic pollutants 
Hg and compounds 

24.2% 
17.2% 
0.9% 
52.7% 

€184,242m 
1238 kt 
€35,360m 
645 kt 
€24,529m 
1156 kt 
€3,393m 
41 kt 
Total value of LCP emissions 

225 kt 
39 t 
24 kg 
15 t 
Total value of emissions excluded 

€736m 
€74 m 
€62m 
€439m 

Table 45 - Energy sector share of industry emissions and damage costs 

*From Industrial Emissions Portal 
+From costs of air pollution from European industrial facilities 2008–2017 

Electricity 
share of 
damage cost 

€112,019m 
€23,620m 
€12,093m 
€994m 
€148,726m 

€178m 
€13m 
€0.6m 
€231m 
€422m 

As  the  table  shows,  addressing  GHG,  acidification  and  PM  emissions  will  cover  around 
99.7% of the expected damage costs of all these emissions to air. In view of this emissions of 
NMVOC, PAH, organic compounds and mercury are not included in the assessment. 

3.  Emissions to water 

The ecoreport tool  can produce outputs showing  heavy metals  and eutrophication.  Table 46 
provides  the  total  value  of  industry  emissions  from  the  European  Pollutant  Release  and 
Transfer Register (EPRTR) and the energy shares of these in industrial emissions. 

Emissions to water 

Industry share in 
total emissions# 
≈50% 
≈35% 
≈25% 
≈10% 
Table 46 - Reported pollutant emissions from large EU industrial installations 

Energy share of 
industry* 
4.1% 
2.3% 
3.1% 
1.7% 

Total industry 
emissions 
5 t 
21 t 
81 t 
246 kt 

Hg 
Cd 
Pb 
N2 

*From Industrial Emissions Portal 
#From contribution of industry to pollutant emissions to air and water 

As  shown  in  the  last  column,  for  emissions  to  water  the  study  on  industry  contribution  to 
emissions showed that industry represent between a quarter and a half of emissions of various 
metals and around 10% of nitrogen. 

74 ETC/ATNI 2020/4; Costs of air pollution from European industrial facilities 2008–2017; July 2021 

163 

 
 
 
 
 
 
 
This  implies  that  for  the  metals  shown,  the  importance  of  the  energy  sector  emissions  will 
range  from  less than 1% to  a maximum of 2% of their emissions and therefore the level  of 
change in these will be of minor impact. For nutrient emissions the energy sector share is even 
smaller,  representing  around  0.2%  of  nutrient  emissions  and  therefore  any  changes  to  these 
emissions can be disregarded. 

In general, it has been accepted to not be possible to establish generalised damage costs for 
emissions to water. This is acknowledged for example in the handbook for InvestEU75, which 
notes ‘difficulties that arise in trying to place a monetary value on such impacts’. This also 
illustrates that it is difficult to arrive at any valid trade-off between these emissions and any 
other impacts. 

4.  Conclusions 

For emissions to air, assessing the impacts on emissions of CO2, acidification (SOx and NOx) 
and PM are shown to represent around 99.7% of the damage value of emissions to air that can 
be assessed using the ecoreport tool. In view of this, reporting the other emissions would not 
bring any added value. 

For emissions to water it has been shown that for the emissions available from the ecoreport 
tool,  the  energy  share  of  total  emissions  is  so  small  that  the  change  that  will  be  induced  in 
them will be irrelevant. Since there is no agreed method for valuing these emissions, it is in 
any case impossible to explore any economic trade-offs between them and other impacts. 

75  Technical  Support  Document  for  Environmental  Proofing  of  Investments  funded  under  the  InvestEU 
Programme 

164 

 
 
 
 
 
 
ANNEX 13: SENSITIVITY TESTS 

1.  Overview 

There are a range of uncertainties underlying the analysis that has been carried out in support 
of  this  Impact  Assessment.  To  assess  how  vulnerable  the  results  are  to  these  uncertainties 
sensitivity tests have been carried out where the various parameters are varied one by one to 
assess the effect on the outcome. 

The largest uncertainty is considered to be how consumers will react to interoperable EPS and 
the resulting impact on EPS purchases.  

A possible uncertainty is the weight attached to the two specific objectives and whether this 
will alter the choice of preferred option.  

A further uncertainty relates to the effect of differing time preference for money. 

Finally the thresholds chosen to translate the estimated effectiveness and efficiency of options 
could affect the ranking of the POs. 

There is of course uncertainty over cost and price assumptions, but no specific sensitivity test 
is  carried  out  on  these  since  it  is  considered  their  impacts  will  be  far  smaller  than  the  tests 
done. 

2.  Consumer reaction to interoperability 

A main uncertainty in assessing the impact of interoperability is how this will affect consumer 
behaviour. The underlying hypothesis  is  that if EPS are interoperable, consumers will reuse 
them for other devices rather than buying a new one with every new end device. Clearly not 
all devices can be powered with all EPS and EPS themselves have finite lives and consumers 
may have a preference to stock more EPS to have them available in different locations.  

The baseline assumption used in the analysis is that the average life of all EPS will increase 
by 50% when they are interoperable. To explore the assumption about how much longer each 
EPS will be used this 50% lifetime increase is varied. A lower variant is explored where it is 
assumed  that  the  lifetime  only  increases  by  25%  i.e.  1/2  of  the  central  assumption.  A 
comparable upper variant assumes that the lifetime of EPS increases on average by 75% ie 1.5 
times the central assumption. 

It  is  to  be  noted  that  the  assumption  about  the  degree  of  reuse  of  EPS,  and  therefore  any 
change for a sensitivity test, must be applied equally to EPS that are used for RED devices as 
well as those that are used for other devices not in the RED scope. The implication of this is 
that the change in this assumption also affects the BAU and affects PO1 that does not itself 
introduce  additional  interoperability  requirements  beyond  those  already  resulting  from  the 
RED.  

The impacts of changes  in the assumed reaction to interoperable EPS will only appear after 
the  initial  period  when  the  EPS  stock  are  not  interoperable.  In  2030  there  should  be  no 
significant  impacts  since  the  cost  of  implementing  the  interoperability  requirements  will  be 
identical, but those EPS will not yet have reached the end of their lives. By 2035 those effects 
should be visible and so comparisons are made of the estimated impacts of the sensitivity tests 
in 2035 compared with the central scenario.   

165 

 
 
 
 
 
Impacts of an EPS life extension due to interoperability above the central case 

Table 47 shows the key results for the central scenario and the sensitivity test with a longer 
life in 2035. It can be seen from the colouring that with the exception of the consumer costs 
savings, there is  relatively  little change in  the ordering of the impacts.  The most  significant 
impacts  are seen on  consumer cost  savings where the ordering is  altered  and PO4 and PO6 
become  the  best  performing  while  PO1  goes  from  best  to  worst  performing.  As  noted,  the 
change  in  the  impacts  of  PO1  is  primarily  because  of  the  assumed  longer  lives  of  RED 
devices.  

Table 47 - Comparison of benefits with an assumed 50% life increase (left) and 75% life increase (right) 

Table 48 below shows the change in impacts with the sensitivity test compared to the central 
scenario  in  absolute  and  percentage  terms.  Cells  coloured  green  show  an  improvement  and 
those coloured red a deterioration compared to the central scenario. As would be expected, the 
impacts  mainly  linked  to  EPS  production  (e.g.  emissions)  mostly  see  a  reduction  of  around 
50%. Gross Energy Requirement decreases less since a large share of this relates to EPS use 
that is unaffected. 

Table 48 - Change in impacts due to 50% increase in EPS life assumption 

166 

Central scenario - 50% longer EPS life due to interoperabilitySensitivity test - 75% longer life due to interoperabilityPO11436.770.020.240.000.020.00PO13157.250.050.251.510.170.05PO2111.610.060.034.010.450.09PO24202.320.10-0.216.480.710.16PO3-102.610.060.064.010.450.09PO34043.320.100.046.480.710.16PO41011.800.070.034.650.520.11PO44872.470.11-0.036.970.760.17PO5822.800.070.074.650.520.11PO54733.470.110.046.970.760.17PO61012.450.070.054.650.520.11PO64893.120.11-0.016.970.760.17PO7942.400.070.054.570.500.10PO74823.070.110.006.890.740.17PO8873.770.080.104.650.520.11PO84804.440.110.056.970.760.17PO9366.880.090.214.650.530.11PO94447.550.120.116.970.770.17Estimated savings with PO in Base caseEstimated savings with PO in longer life caseGross Energy Requirement savingGHG savingFuel combusted savedE-waste avoidedAcidification emissions avoidedPM emissions avoidedConsumer cost savingPM emissions avoidedConsumer cost savingGross Energy Requirement savingGHG savingFuel combusted savedE-waste avoidedAcidification emissions avoidedEffect of a 50% higher EPS life increase due to interoperability compared to the central assumptionPO1172120%0.497%0.03128%0.001%1.51INF0.15628%0.055515%PO24093710%0.7245%0.0469%-0.24-870%2.4661%0.2657%0.0779%PO3414######0.7227%0.0465%-0.03-44%2.4661%0.2656%0.0779%PO4386381%0.6737%0.0454%-0.06-219%2.3150%0.2446%0.0661%PO5391478%0.6724%0.0452%-0.03-45%2.3150%0.2446%0.0661%PO6388384%0.6727%0.0453%-0.07-124%2.3150%0.2446%0.0661%PO7388415%0.6728%0.0455%-0.05-101%2.3151%0.2448%0.0664%PO8393452%0.6718%0.0450%-0.05-52%2.3150%0.2446%0.0661%PO94091147%0.6710%0.0444%-0.10-47%2.3150%0.2445%0.0661%Change in PM saving as % of base caseFuel combusted savedE-waste avoidedAcidification emissions avoidedPM emissions avoidedChange in consumer saving as % of base caseChange in GER saving as % of base caseChange in GHG saving as % of base caseChange in fuel saving as % of base caseChange in e-waste saving as % of base caseChange in acidification saving as % of base caseAdditional benefit from longer life vs Base caseConsumer cost savingGross Energy Requirement savingGHG saving 
 
 
 
 
 
Impacts of an EPS life extension due to interoperability less than the central case 

Table 49 below shows the key results for the central scenario and the sensitivity test with a 
shorter life in 2035. It can be seen from the colouring that there is relatively little change in 
the ordering of the impacts. 

Table 49 - Comparison of benefits with an assumed 50% life increase (left) and 25% life increase (right) 

Table 50 below shows the change in impacts with the sensitivity test compared to the central 
scenario  in  absolute  and  percentage  terms.  Cells  coloured  green  show  an  improvement  and 
those coloured red a deterioration compared to the central scenario. As would be expected, all 
impacts are worse than in the central case. 

Table 50 - Change in impacts due to 50% decrease in EPS life extension assumption 

3.  Weighting of the specific objectives 

To test the sensitivity of the assessment of effectiveness and efficiency to the assumed share 
of SO1 and SO2 in the assessment a range of shares were tested as shown in Table 51 below. 
The central case assumes both are equally important. The moderate variants increase the share 
of  one  or  the  other  to  60%,  the  extreme  variants  to  70%  and  the  most  extreme  (EU  focus) 

167 

Central scenario - 50% longer EPS life due to interoperabilitySensitivity test - 25% longer life due to interoperabilityPO11436.770.020.240.000.020.00PO11406.750.020.240.000.020.00PO2111.610.060.034.010.450.09PO2-3991.200.04-0.222.440.270.05PO3-102.610.060.064.010.450.09PO3-4292.210.040.042.440.280.05PO41011.800.070.034.650.520.11PO4-2651.480.05-0.033.370.370.08PO5822.800.070.074.650.520.11PO5-2932.480.060.043.370.370.08PO61012.450.070.054.650.520.11PO6-2692.130.05-0.013.370.370.08PO7942.400.070.054.570.500.10PO7-2762.080.050.003.280.360.08PO8873.770.080.104.650.520.11PO8-2913.460.060.053.370.380.08PO9366.880.090.214.650.530.11PO9-3666.570.070.113.370.390.08PM emissions avoidedGross Energy Requirement savingGHG savingFuel combusted savedE-waste avoidedAcidification emissions avoidedE-waste avoidedAcidification emissions avoidedPM emissions avoidedEstimated savings with PO in longer life caseConsumer cost savingEstimated savings with PO in Base caseConsumer cost savingGross Energy Requirement savingGHG savingFuel combusted savedEffect of a 50% lower EPS life increase due to interoperability compared to the central assumptionPO1-3-2%-0.010%0.00-2%0.000%0.00INF0.00-11%0.00-55%PO2-410######-0.40-25%-0.02-38%-0.25-885%-1.57-39%-0.18-39%-0.03-38%PO3-4194234%-0.40-15%-0.02-36%-0.03-43%-1.57-39%-0.18-39%-0.03-38%PO4-366-361%-0.32-18%-0.02-25%-0.06-217%-1.29-28%-0.15-28%-0.03-24%PO5-374-458%-0.31-11%-0.02-24%-0.03-45%-1.29-28%-0.15-28%-0.03-24%PO6-370-366%-0.32-13%-0.02-24%-0.07-124%-1.29-28%-0.15-28%-0.03-24%PO7-370-395%-0.32-13%-0.02-25%-0.05-101%-1.29-28%-0.15-29%-0.03-25%PO8-378-435%-0.31-8%-0.02-23%-0.05-52%-1.29-28%-0.15-28%-0.03-24%PO9-402######-0.31-5%-0.02-20%-0.10-47%-1.29-28%-0.15-27%-0.03-24%Change in PM saving as % of base caseE-waste avoidedChange in e-waste saving as % of base caseAcidification emissions avoidedChange in acidification saving as % of base casePM emissions avoidedChange in GER saving as % of base caseGHG savingChange in GHG saving as % of base caseFuel combusted savedChange in fuel saving as % of base caseAdditional benefit from longer life vs Base caseConsumer cost savingChange in consumer saving as % of base caseGross Energy Requirement saving 
 
 
 
 
assumes a 90% share for energy and GHG emissions are counted as 90% of the SO2 impact 
(as opposed to 37% in the other scenarios).  

Table 51 - Weighting of SO1 and SO2 for sensitivity tests 

The EU focus scenario is intended to reflect the fact that most of the pollutant emissions other 
than Greenhouse gas will occur outside the EU and have most of their impacts outside the EU. 
In  contrast  the  majority  of  the  energy  use  will  occur  in  the  EU  and  have  a  cost  for  EU 
consumers while the GHG emissions have global impacts and are therefore equally important 
for the EU regardless of where they are emitted. 

4.  Effectiveness  

Table 52 shows the normalised results for the Central scenario and full set of sensitivity tests 
for effectiveness. The range of effectiveness is 51% in the Central scenario and increases in 
almost all sensitivity test to reach a maximum of 66% in EU focus. In ModVAR1 the range 
decreases slightly to 55% variation in effectiveness.  

Table 52 - Normalised outcomes of the sensitivity tests of Effectiveness contrasted with the Central scenario 

It  can  be  readily  seen  from  the  heat  colouring  that  the  sensitivity  tests  do  not  show  any 
significant  sensitivity  in  the  ordering  of  the  results  except  at  the  extremes.  PO9  is  in  all 
scenarios the most effective option. PO1 is generally the least effective except if a very strong 
emphasis  is  placed  on  energy  saving  compared  to  environmental  impacts.  PO2  is  generally 
the second worst performing although with an extreme focus on energy it replaces PO1 as the 
least effective.  

For PO3 to PO8 the order of effectiveness from least to best is PO3, PO4, PO7, PO6, PO5, 
PO8  for  the  Central,  Moderate  and  Ext  VAR2  scenarios.  PO3  and  PO4  swap  places  in  Ext 
VAR1 and in EU focus PO3 improves position to perform as well as PO6 but the ordering of 
the other POs does not change. 

168 

SO1 (energy)SO2 (emissions)CENTRAL50%50%MOD VAR 160%40%MOD VAR 240%60%EXT VAR 170%30%EXT VAR 230%70%EU FOCUS90%10%90% energyEnergy EmissionsEnergy Emissions9% GHGPOCENTRALMod VAR 1Mod VAR 2Ext VAR 1Ext VAR 2EU focusPO10.490.570.420.670.370.88PO20.600.550.650.480.680.34PO30.660.620.700.570.720.46PO40.680.620.740.550.780.38PO50.750.700.790.630.820.50PO60.720.670.770.600.810.46PO70.700.650.750.590.780.45PO80.810.770.840.720.860.62PO91.001.001.001.001.001.00Moderate emphasis on:Strong emphasis on: 
 
 
 
The  broad  similarity  in  the  results  of  the  sensitivity  test  can  be  attributed  to  the  fact  that  a 
large share of all the impacts are closely correlated with the electricity consumption in the use 
phase of the EPS which was shown as around 78% in Table 2 and which will be even higher 
when interoperability leads to longer EPS operating lives. 

These effects are shown graphically in the radar plot below where the most obvious effect is 
that there is virtually no changes in the relative effectiveness axis of PO2 to PO9, however as 
noted for PO1 the sensitivity tests significantly alter its attractiveness.  

Figure 63 - Radar plot of sensitivity impacts on normalised effectiveness of PO1 to PO9 

5.  Efficiency 

Efficiency  is  assessed  on  the  basis  of  the  effect  of  the  POs  on  consumer  costs.  It  must  be 
borne  in  mind  that  the  cost  impacts  of  the  various  measures  occur  in  different  time  frames. 
Some result immediately in increased EPS purchase prices while others only occur at the end 
of  the  EPS  life  when  a  new  EPS  needs  to  be  purchased  and  the  effect  of  the  efficiency 
measures  is  felt  throughout  the  life.  To  take  account  of  these  temporal  differences  it  is 
necessary to  use a discount rate to  account  for the higher preference for  money in  the short 
term. A 3% discount rate is used as the central hypothesis but sensitivity tests with a 0% and 
6% rate are carried out. 

a)  No discounting 

Table 53 shows the full set of sensitivity tests for efficiency without discounting for the same 
options and sensitivities as effectiveness. The central case shows an 83% efficiency range. In 
the  other  scenarios  this  range  either  increases  to  88%  (ExtVAR2)  or  86%  (ModVAR2)  or 
decreases  to 73% (ExtVAR1), 77% (EU focus) or 79% (ModVAR1). 

In terms of the ordering of the efficiency of the POs, PO1 is the most efficient in all scenarios 
except EU focus. PO3 is the least effective in all scenarios. PO2 and PO9 are then the next 
least  efficient  changing  order  depending  on  whether  the  focus  is  on  energy  (PO9  less 
efficient) or emissions (PO2 less efficient).  

It  is  noticeable  that  with  a  greater  emphasis  on  energy  rather  than  emissions  PO4,  6  and  7 
appear significantly more efficient and PO4 actually becomes the most efficient with a very 
high energy focus. 

169 

 
 
 
Table 53 - Normalised outcomes of efficiency sensitivity tests with no discounting 

b)  3% discount rate 

Using  a  3%  discount  rate  will  means  that  the  present  value  of  the  electricity  savings  in  use 
will be valued less highly while the reduced EPS purchase costs at the end of life will be even 
further  discounted  compared  to  the  case  with  no  discounting.  The  results  of  the  sensitivity 
tests in this case are shown in Table 54. 

Table 54 - Normalised outcome of efficiency sensitivity tests with 3% discounting 

In  terms  of  the  range  of  variation  between  the  scenarios,  there  is  no  difference  with  the 
scenarios  without  discounting.  There  is  no  particularly  significant  change  in  the  relative 
ordering  of  the  POs  with  the  different  scenarios  with  3%  discount  rate  compared  to  no 
discounting.  

c)  6% discount rate 

The  results  using  a  6%  discount  rate  are  shown  in  Table  55  below.  In  this  case  the  present 
value of the electricity savings in use will be valued even less highly while the reduced EPS 
purchase costs at  the end of life  will be even further discounted.  Although  there  are further 
small differences the overall ranking of the POs is unchanged.  

170 

90% energyEnergy EmissionsEnergy Emissions9% GHGPOCENTRALMod VAR 1Mod VAR 2Ext VAR 1Ext VAR 2EU focusPO11.001.001.001.001.000.53PO20.280.360.220.470.190.47PO30.170.210.140.270.120.23PO40.590.750.461.000.391.00PO50.470.590.380.750.320.66PO60.550.690.440.900.380.83PO70.540.680.430.880.370.80PO80.450.550.370.690.320.56PO90.280.320.240.380.210.26Moderate emphasis on:Strong emphasis on:90% energyEnergy EmissionsEnergy Emissions9% GHGPOCENTRALMod VAR 1Mod VAR 2Ext VAR 1Ext VAR 2EU focusPO11.001.001.001.001.000.59PO20.260.330.200.440.170.48PO30.170.210.140.270.120.26PO40.520.670.410.890.351.00PO50.430.540.350.690.300.68PO60.500.630.400.820.340.84PO70.490.610.390.800.340.82PO80.430.520.350.650.300.59PO90.260.300.220.350.200.28Moderate emphasis on:Strong emphasis on: 
 
 
 
Table 55 - Normalised outcome of efficiency sensitivity tests with 6% discounting 

These  effects  are  shown  graphically  in  the  radar  plots  in  Figure  64  for  the  three  levels  of 
discounting. 

Figure 64 - Radar plots showing sensitivity impacts on normalised efficiency of the POs 

The radar plots illustrate that there is no really significant variation across the three sensitivity 
tests in terms of the ranking of the POs. It is really only in the most extreme cases (EU focus 
and Ext VAR1) that there is a noticeable impact in the rankings. 

6.  Effects of the effectiveness and efficiency sensitivity tests on ranking off the POs. 

The  sensitivity  tests  have  shown  that  varying  the  importance  given  to  SO1  and  SO2  in  the 
scoring  does  not  lead  to  very  significant  changes  in  the  actual  scoring  of  effectiveness  and 
efficiency. Nonetheless, it is important to check whether these changed weights would lead to 
a different ranking of the POs or the choice is robust regardless. The results of this are shown 
in  Table  56  without  discounting.  In  this  table  the  scoring  for  LLCC  and  coherence  (shown 

171 

90% energyEnergy EmissionsEnergy Emissions9% GHGPOCENTRALMod VAR 1Mod VAR 2Ext VAR 1Ext VAR 2EU focusPO11.001.001.001.001.000.67PO20.240.300.190.400.160.50PO30.160.200.130.260.110.28PO40.460.590.370.790.311.00PO50.400.500.320.640.270.71PO60.450.570.360.740.310.86PO70.450.560.360.730.300.83PO80.400.490.330.610.280.63PO90.240.280.200.320.180.29Moderate emphasis on:Strong emphasis on: 
 
 
 
 
shaded) are held constant In the right hand side are shown the final scores, coloured green for 
best, yellow for second best and red for third best. 

Table 56 - Final rankings using effectiveness and efficiency scores from the sensitivity tests 

In the central scenario and 4 out of the 5 sensitivity tests, PO6 scores highest. In ModVAR1 it 
scores  equally  well  with  PO4  and  PO8.  Those  two  POs,  along  with  PO7  score  fairly 
consistently in joint second place in the rankings. 

7.  Effects of the weighting applied to LLCC on ranking of the POs. 

In the ranking of the POs, the approach followed means that a maximum score of 2 is given 
for LLCC, maximum 3 each for effectiveness and efficiency and maximum 2 for coherence 
giving a maximum score of 10 and a 20% weight for LLCC in the maximum score. Since the 
LLCC requirement is clearly stated, subject to taking account of the environmental impacts, it 
is desirable to see whether giving a higher weight to LLCC in the scoring leads to any change 
in the ranking of the POs. 

For this test the scores from the sensitivity tests for effectiveness and efficiency are used, and 
these  along  with  the  scores  for  coherence  are  held  constant  (shown  shaded  in  Table  57).  In 
contrast, the scores for LLCC are doubled, increasing the LLCC weight from a maximum of 
20% to maximum of 33% in the final scoring. 

The highest ranked PO in each scenario is shown in green, the second best in yellow and the 
third best in red. A clear impact of the increased emphasis on LLCC is to increase the clarity 
that PO6 is the best ranked PO in all sensitivity tests, always scoring better than any other PO. 
PO1, 4, 7 and 8 remain the other best scoring POs although their rankings change and PO1 is 
now second or joint second best in many of the cases. 

This  sensitivity  test  tends  to  confirm  that  PO6  is  the  best  performing  given  the  LLCC  cost 
constraint. 

172 

No discountingPOLLCCCoherenceEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyPO1201313231332666767PO2111121112111445454PO3011121112111334343PO4121322132113777767PO5021221123112555565PO6221222133113878888PO7121222132113767767PO8122231223122677777PO9023131313131666666EU focusEffectiveness and efficiency score by scenarioOverall scoring of the POsCentralModVAR1ModVAR2ExtVAR1ExtVAR2EU focusModVAR1ModVAR2ExtVAR1ExtVAR2 
 
 
Table 57 - Impact of increased LLCC weight in rankings 

8.  Societal costs 

A further sensitivity is to see whether using societal costs rather than consumer costs changes 
the results. The results of this test are shown in the table and radar plot in Figure 65 below. 

Figure 65 - Table and radar plot showing societal cost efficiency of the POs 

The  most  noticeable  change  compared  to  using  consumer  costs,  is  that  there  is  a  slightly 
smaller  efficiency  range  across  the  POs.  With  the  central  scenario  the  range  is  73%  which 
increases  to  a  maximum  of  81%  in  ExtVAR2  and  decreases  to  a  minimum  of  63%  in 

173 

No discountingPOLLCCCoherenceEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyPO1401313231332688989PO2211121112111456565PO3011121112111334343PO4221322132113788878PO5021221123112555565PO64212221331138910101010PO7221222132113778878PO8222231223122688888PO9023131313131666666Effectiveness and efficiency score by scenarioOverall scoring of the POsModVAR1ModVAR2ExtVAR1ExtVAR2EU focusCentralModVAR1ModVAR2ExtVAR1ExtVAR2EU focus90% energyEnergy EmissionsEnergy Emissions9% GHGPOCENTRALMod VAR 1Mod VAR 2Ext VAR 1Ext VAR 2EU focusPO11.001.001.000.861.000.46PO20.390.490.300.560.260.55PO30.270.340.220.370.190.32PO40.680.870.541.000.451.00PO50.560.700.450.770.390.68PO60.640.810.510.900.440.83PO70.630.790.500.890.430.81PO80.540.650.440.700.380.57PO90.360.410.300.420.270.29Strong emphasis on:Moderate emphasis on: 
 
 
 
 
ExtVAR1. The main reason these scenarios lead to the largest variation in both directions is 
because the  emissions to  air  are included in  both the denominator and the numerator of the 
calculation and so the change in their importance is thus exaggerated in both directions.  

While there are some differences compared to efficiency based on consumer cost,  it  can be 
concluded that using societal costs as the basis for assessing cost efficiency does not lead to 
any substantial change in the cost efficiency ranking of the POs. 

Table 58 - Ranking of POs based on societal costs 

Table  58  shows  that  the  final  rankings  of  the  POs  based  upon  societal  costs  rather  than 
consumer  cost  are  largely  unchanged.  The  entries  shown  shaded  are  unchanged  in  this 
assessment. The clear best performing option remains PO6, with PO4, 7 and 8 the second best 
and PO1 and 9 third ranked. This is in line with the results of using the other sensitivity tests 
to produce rankings of the POs. 

9.  Impact of the thresholds for effectiveness and efficiency 

As explained in section 7.4, the calculated values of effectiveness and efficiency are translated 
into a scoring of 1 to 3 to enable ranking of the POs. If the scores are translated to the same 
scale  using  figures  to  one  decimal  place  instead  of  integers  the  ranking  might  change.  The 
effect of this test is shown in table below. 

Table 59 - Comparison of ranking POs with integers or to one decimal place 

It can be seen that there is no significant impact on the rankings. The most noteworthy change 
is that PO8 scores slightly better with decimals and ranks second instead of joint third while 
PO4 scores slightly worse with decimals and ranks joint third instead of joint second.  

These minor changes in ranking should be contrasted with the necessarily quite basic scoring 
of LLCC and coherence as tested for example in point 7 above. 

174 

Societal impactsPOLLCCCoherenceEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyEffectivenessEfficiencyPO120131313231331666766PO211111121112112445455PO301111121112111334343PO412221322132113777767PO502211221123112555565PO622221322133113888888PO712221322132113777767PO812212231223122677777PO902313131313131666666CentralEffectiveness and efficiency score by scenarioOverall scoring of the POsModVAR1ModVAR2ExtVAR1ExtVAR2EU focusCentralModVAR1ModVAR2ExtVAR1ExtVAR2EU focusPO1PO2PO3PO4PO5PO6PO7PO8PO9Original643758766With decimals6.04.63.06.65.67.76.66.96.2 
 
 
 
  
 
ANNEX 14: ADDITIONAL IMPACTS OF THE POLICY OPTIONS 

Main indicators for POs in 2030: 

Table 60 - Main indicators of PO impacts in 2030 with colour coding 

Main indicators for POs in 2040: 

Table 61 - Main indicators of PO impacts in 2040 with colour coding 

175 

optionEU27 Societal Life Cycle Costs (€m)Total EU27 annual consumer expenditure (€m)Thereof EU27 purchase price total (€m)Thereof EU27 electricity total (€m)Greenhouse Gases (Mt CO2eq)Total Energy (GER) (PJ)Total weight (=e-waste) (kt)Acidification emissions (kt SO2eq)Particulate Matter (PM, dust)  (kt)BAU73306998516718311.18475.43131.7843.6530.822PO172266903519917041.13870.84331.7843.6270.821PO277297409553518731.16376.30529.3183.3850.768PO377507431558618461.15375.30829.3183.3790.768PO476527336546218731.15376.13128.7493.3260.751PO576727357551218461.14375.13428.7493.3200.751PO676527337548118561.14775.51428.7493.3230.751PO776617344548818561.14975.56028.8313.3380.755PO876647351553318181.13374.13828.7493.3150.751PO977197412568117321.10371.04028.7493.2970.750POTotal EU27 annual consumer expenditure (€m)Thereof EU27 purchase price total (€m)Thereof EU27 electricity total (€m)Greenhouse Gases (Mt CO2eq)Total Energy (GER) (PJ)Total weight (=e-waste) (kt)Acidification emissions (kt SO2eq)Particulate Matter (PM, dust)  (kt)BAU7608578718210.59383.96035.6883.8530.895PO17478582716510.59377.12035.6883.8340.894PO27596578918070.53582.34531.6193.3970.806PO37620583817820.53581.34531.6193.3940.806PO47505569818070.52482.14630.9623.3300.787PO57527574517820.52481.14630.9623.3270.787PO67506571617900.52481.46030.9623.3280.787PO77514572417900.52681.51331.0443.3430.791PO87524576517580.52480.19630.9623.3240.787PO97583590316810.52477.07230.9623.3160.786 
 
 
 
 
 
 
Figure 66 - Graphs showing (left) purchase price impacts and (right) electricity cost impacts of BAU and the 
POs from 2020 to 2040 

Figure 67 - Graphs showing (left) acidification and right particulate matter emissions of BAU and the POs from 
2020 to 2040 

Figure 68 - Cumulative costs of the POs versus BAU for 5 year periods to 2045 

176 

 
 
 
 
 
 
ANNEX 15: VALUING CONSUMER (IN)CONVENIENCE 

Valuation of consumer convenience in this Impact Assessment 

The  core  analysis  carried  out  in  this  Impact  Assessment  focusses  on  the  direct  costs  and 
environmental  impact  of  the  measures  and  policy  options.  However,  a  key  objective  of  the 
Common Charger initiative and an important co-benefit of the interoperability aspects of the 
EPS  review  is  to  increase  consumer  convenience.  The  difficulty  arises  in  quantifying  this 
increase  in  consumer  convenience  in  a  precise  manner.  No  consumer  studies  have  been 
carried out in the course of this work to attempt to allocate monetary values to those benefits. 

Because  of  this  challenge,  the  approach  followed  has  been  to  exclude  the  valuation  of  the 
benefits  of  the  policy  options  for  consumer  convenience  from  the  assessment  of  the 
effectiveness  and  efficiency  of  the  POs.  However,  a  rough  estimation  may  be  made  of  the 
likely scale of the consumer convenience benefits to provide a benchmark to understand the 
likely importance this can have. 

Likely benefits of EPS interoperability for consumer convenience 

The whole motivation for the common charger initiative is predicated on an assumption that 
consumers would value being able to use the same EPS for multiple devices. This would be 
applicable at the same moment in time but also over time as the end device is replaced.  

Additional benefits may arise in the case of failure of an EPS since if they are interoperable, 
another EPS may simply be used to replace the broken one without the need to immediately 
buy a new one. More commonly, in case an EPS is forgotten, and an end device needs to be 
powered or charged, interoperable EPS means that this is feasible using someone else’s EPS. 

Further benefits may arise from a reduced need to carry EPS from one location to another to 
power  a  device,  since  there  will  be  interoperable  EPS  available  at  that  location  that  will  be 
usable with the device. 

The potential to reuse EPS over time is internalised in the analysis by the assumed longer EPS 
lifetimes. Similarly, some of the consumer convenience is already included in the baseline due 
to  the  RED  requirements  for  USB  receptacles  on  the  range  of  RED  end  devices.  What  is 
clearly not internalised are situations where there is: 

•  a need to buy a replacement for a failed or lost non-interoperable EPS; 

•  a need to temporarily use another EPS in case of forgetting a non-interoperable EPS. 

Replacements for failed EPS 

The modelled assumption for durability is that this would lead to an average 2 month longer 
life  for  EPS  assuming  that  average  lifetimes  increase  to  7.5  years.  This  implies  an 
approximate failure rate of 2% over this lifetime. The cost of purchasing the replacement for 
the failed EPS is internalised in the modelling assumptions. However, what is not internalised 
is the inconvenience at the moment of the failure both in terms of the time needed to identify 
and purchase a replacement and the inability to use the powered device in the meantime. 

In the case of non-interoperable EPS it can be assumed that obtaining a replacement will not 
be immediate. In the best case in can be assume that it would need an hour of searching and at 
least a day if not longer wait for the new EPS to be available. We can assume a low hourly 
rate of €10 per hour for the personal  effort involved. For the delay to  using the end device, 
this will clearly vary enormously depending on the what the end device is. A lower limit is 
probably zero, since for many devices the inconvenience would be minimal, while an upper 

177 

 
 
 
limit might be set by the cost of replacing the end device rather than waiting for a replacement 
EPS. It is proposed that the cost of this inconvenience be assumed to be €10 per failure. 

Since there is a total stock of approximately 2bn EPS, of which around 60% will be covered 
by the RED interoperability requirements, the additional consumer convenience will relate to 
the  other  40%  i.e.  800mln  EPS.  Based  on  the  assumed  2%  premature  failure  rate,  this  will 
amount to an average of 16mln EPS failures per year. If the inconvenience to consumers for 
each  failure  is  valued  at  €20  this  would  provide  an  indicative  value  of  the  consumer 
inconvenience from prematurely failing non-interoperable EPS of €320mln per year. 

Clearly  the  fact  that  EPS  would  be  interoperable  cannot  remove  all  the  cost  of  this 
inconvenience.  For  example,  the  failure  might  occur  in  circumstances  where  there  is  no 
alternative EPS available. In view of this it may be reasonable to assume that this represents 
half of the situations and therefore the actual avoided inconvenience may only be around half 
of the estimated value, i.e. €160mln per year. 

Temporary use of another EPS 

The  supporting  study  for  the  Common  Charger  IA  reported  that  for  mobile  phone  users  a 
problem arising from the situation with incompatible EPS was: 

“Consumer inconvenience: Most mobile phone users (84% according to the consumer panel 
survey)  have  experienced  problems  related  to  their  phone  chargers  in  the  last  two  years. 
Commonly cited problems (each experienced by between one third and half of respondents) 
were the inability to charge certain devices (as fast) with certain chargers; having too many 
chargers  taking  up  space  in  the  home  and/or  workplace;  situations  where  they  needed  to 
charge  their  phone,  but  the  available  chargers  were  incompatible  with  it;  and  confusion 
about which charger works with what device. Around 15% to 20% of all survey respondents 
who  experienced  one  or  more  of  these  problems  reported  it  had  caused  them  significant 
issues.” 

This  would  imply  that  around  6%  of  mobile  phone  users  may  have  experienced  significant 
inconvenience due to the lack of interoperability per year. However, this figure cannot readily 
be  translated  to  other  sorts  of  devices  with  EPS  since  by  their  nature  mobile  phones  are 
frequently carried without their EPS while in the majority of cases most end devices are likely 
to be used and remain with their EPS. 

It is therefore supposed that for the non-RED devices, the scale of this problem would be very 
much  smaller,  and  it  hypothesised  to  maybe  be  only  2%  of  the  level  identified  for  mobile 
phone users. This would imply that around 0.1% of EPS users would experience significant 
issues.  This  case  would  apply  to  the  800m  non-RED  EPS  meaning  that  these  difficulties 
would  be  experienced  for  0.8mln  EPS.  If  it  is  assumed  that  the  value  of  these  significant 
difficulties to the consumers is also €10 it would imply a consumer inconvenience of €8mln. 

Network or scale effects 

A further factor that increases consumer convenience is the effect of more devices and EPS 
being  interoperable.  This  scale  effect  increases  the  likelihood  that  a  given  EPS  will  be 
interoperable and therefore substitutable with another one. This scale effect applies to all EPS 
since  even  the  users  of  RED  devices  will  benefit  if  there  are  more  possible  USB  EPS 
available that they could potentially use for their devices. 

The effect means that anyone with any EPS, even users of RED devices, are more likely to 
readily be able to use an alternative EPS when their own one is unavailable. The value of this 
for  users  of  RED  devices  is  calculated  on  the  basis  that  6%  of  users  off  RED  devices  may 
experience  significant  inconvenience  each  year.  If  it  is  assumed  that  there  are  400mln  such 

178 

 
 
users, 24mln per year will suffer significant inconvenience. By increasing the likelihood that 
there is an alternative usable EPS available (by 60%) though ensuring that the remaining 40% 
of non-RED device EPS are also interoperable, the value of this inconvenient will be reduced. 
If the inconvenience is assumed to be inversely related to the availability of interoperable EPS 
it would reduce the inconvenience by 1/3 i.e. by €3.3 based on the assumed value of €10 per 
significant  inconvenience.    This  improved  consumer  convenience  from  the  scale  effect  is 
therefore worth around €79mln per year. 

Summary and conclusions 

Two  possible  types  of  consumer  inconvenience  have  been  identified  that  the  increased 
interoperability  of  non-RED  EPS  will  alleviate.  A  third  benefit  is  identified  based  on  the 
network effects from a wider range of interoperable EPS. The central estimated values for the 
three different effect are shown below with an indication of how large the values might be if 
they were either 50% lower or 50% higher than the estimate.  

Figure 69 - Illustrative ranges of estimated consumer convenience benefits 

Based on these very approximate estimates the additional value of the consumer convenience 
arising due to the interoperability requirements envisaged in M3 and included in PO2 to PO9 
range between a low of €123mln and a high of €370mln per year with a central estimate of 
around €250mln. 

179 

 
 
 
 
 
ANNEX 16: EVIDENCE UNDERLYING ASSUMPTIONS OF EXTENDED 
INTEROPERABLE EPS LIFETIMES 

One of the major reasons for the assumed environmental benefits from interoperable EPS is 
that  consumers  will  continue  to  use  the  same  EPS  with  other  products  even  if  the  end-use 
product reaches the end of its life. Coupled with this is an assumption that manufacturers will 
progressively choose to unbundle the sales of end-use products from EPS as the latter become 
interoperable. 

There is little hard evidence that can support these assumptions since the traditional business 
model  involved  an  EPS  being  supplied  with  each  end-use  product  and  therefore  implicitly 
being disposed of when the end-use product reached the end of its life. 

This  annex  brings  together  a  range  of  information  sources  that  by  analogy  can  be  used  to 
arrive  at  plausible  assumptions  about  the  likely  rate  of  reuse  of  EPS  and  their  increased 
lifetime. 

Work carried out for the revision of the Radio Equipment Directive 

In the 2021 Impact Assessment study on unbundling of chargers some data was given on the 
state of unbundling for various related products. This showed the following shares at that time 
that were sold without an EPS or charger:  

Product 

Number reviewed 

Proportion without EPS or charger 

Mobile phone 

186 

Tablet 

Camera 

Hearing aids 

Video game consoles 

Portable speakers 

E-readers 

Smart watches 

Not known 

29 

34 

9 

26 

8 

11 

17% 

0% 

28% 

100% 

22% 

81% 

100% 

55% 

Table 62 - Share of unbundled EPS for various products from 2021 Impact Assessment 

It should be recalled that at the time there were no requirements relating to unbundling. While 
no survey has been carried out  to  assess how these figures have  evolved, there is  anecdotal 
evidence of a trend towards unbundling with for example many tablets now offered without 
EPS.  

The  2019  public  consultation  that  was  carried  out  for  the  review  of  the  Radio  Equipment 
Directive received 2,850 responses. An overwhelming majority (96%) were EU citizens, with 
all Member States represented. Most citizens were not satisfied with the existing situation and 
76%  agreed  or  strongly  agreed  that  it  was  a  source  of  inconvenience  (because  of  multiple 
chargers  for  different  devices  taking  up  space  in  their  homes  or  generating  confusion,  or 
difficulties  finding  a  suitable  charger  when  away  from  home).  This  consumer  reaction 
suggests  a  strong  interest  in  purchasing  less  EPS  and  reusing  them  from  one  device  to 
another. 

Manufacturer willingness to offer other products without EPS – i.e. unbundling 

180 

 
 
Examples can be found  for many products such  as  monitors76, battery chargers77, grooming 
tools78, power banks79, bike lights80. While no data is available on market shares for USB-C 
power  supply  for  these  types  of  products  their  existence  clearly  demonstrates  a  consumer 
demand for them and willingness on behalf of manufacturers to supply this.  

Consumer reasons for disposing of other products  

EPS are essentially functional devices rather than fashionable ones. They are not something 
that  have  a  status  value  but  are  rather  kept  out  of  the  way  and  largely  carry  out  their  job 
unseen. In view of this they may be considered like other functional household equipment. 
The PROMPT81 project investigated causes for disposing of five types of household electrical 
and  electronic  equipment82.  It  showed  that  the  rate  at  which  these  were  kept  in  use  until 
defective varied substantially according to the type of equipment as shown in Table 63. 

Equipment 

Washing machine 

Vacuum cleaner 

Television 

Smartphone 

Proportion replaced 
because defective 

Proportion replaced 
because not working well 

69% 

34% 

44% 

29% 

Around 30% 

Around 10 to 20% 

Table 63 - PROMPT data on the share of various products used till defective 

Although they relate to very different types of products and these products have very different 
functions from EPS it is interesting to note that somewhere between a minimum of 30% and a 
maximum of 69% of respondents appear to be willing to continue using these products while 
they are sufficiently functional. 

Other evidence of consumer interest in prolonging product lives  

The  Impact  Assessment  for  the  Ecodesign  for  Sustainable  Products  Regulation  (ESPR)  
argues  that  many  individual  are  interested  in  prolonging  the  lives  of  products  but  are 
hampered by a range of factors: 

“Similarly,  as  information  on  the  lifespan  of  products  is  regularly  not  available  to 
consumers, they often use other indicators (e.g. price or brand) to gauge the durability 
of  the  goods.  This  often  leads  to  consumers  associating  more  expensive  goods  with 
longer lifespans, despite the fact that consumer organisations point out that “in non-

76 https://www.visionect.com/shop/place-play-32/  

77 https://www.amazon.co.uk/usb-battery-charger/s?k=usb+battery+charger  

78 https://www.amazon.com.be/-/nl/Multistyle-opzetkammen-maaihoogtes-MG7930-
15/dp/B0CG6VGPM4?th=1 
79 https://www.amazon.com.be/-/en/Anker-PowerCore-Essential-20000-Technology/dp/B07S829LBX 

80 https://www.amazon.com.be/-/en/SIGMA-SPORT-Blaze-Function-Approved/dp/B07YMZQNVK 

81 Premature Obsolescence Multi-Stakeholder Product Testing Program 

82 PROMPT Deliverable 2.6 

181 

 
 
 
 
 
transparent  markets  high  purchase  prices  are  not  always  good  indicators  for  the 
durability of products”. Ultimately, the lack of information on a product’s durability 
can  lead  to  sub-optimal  purchase  choices,  with  consumers  unknowingly  purchasing 
goods  that  are  potentially  more  difficult  to  repair  or  that  have  worse  software 
update/upgrade  policies than  the  available  alternatives,  in  turn  leading  to  increased 
‘hassle costs’ (e.g. related to efforts and expenses with organising repair or replacing 
the good).” 

It stated that in a 2018 public consultation, 83.4% responded that ‘the EU should set rules to 
make sure products have a long lifetime’. 

The  measures  envisaged  for  EPS  would  aim  to  remove  the  uncertainties  for  consumers 
through ensuring that EPS are reusable by consumers without any effort on their behalf. 

The ESPR IA also states that among EU citizens: 

•  56% are ‘occasional’ consumers of environmentally friendly products; 
•  23% pay attention to the environmental impact of all or most goods and services; 
•  67% buy products that are better for the environment even if they cost more;  
•  56% would use the information to buy ‘more environmentally friendly’ products.  

While none of these statements exactly relates to the reuse of EPS, the latter behaviour is in 
line  with  the  statements  in  that  it  is  more  environmentally  friendly  by  reducing  the 
environmental  impact  form  EPS  production,  it  would  in  fact  cost  less,  not  more,  and  by 
avoiding the need for a new EPS makes new end-use products more environmentally friendly. 
A consumer behavioural study83 in 2018 explored consumer attitudes. Some relevant findings 
from that survey are set out below: 

Concerning how long consumers wish to use products it was stated that:  

‘With respect to  keeping things for a long time, agreement rates  were high. Overall, 
93% agreed to this statement with 42% even stating strong agreement.’   

However, interestingly the statements on whether they always buy new the newest electronic 
goods  and  gadgets  was  almost  completely  balanced  implying  that  there  is  a  disconnect 
between  the  two  statements.  Enabling  EPS  to  be  used  longer  offers  a  route  to  partially 
reconcile these two wishes of consumers. 

The survey also showed:  

‘consumers’  significant  willingness-to-pay  for  better  durability/reparability  for  all 
product  categories.  Depending  on  how  durability/reparability  information  was 
presented, willingness-to-pay for an additional year of durability ranged between €20-
36 
for 
smartphones’.  

for  vacuum  cleaners  and  dishwashers,  €92-148 

for  TVs,  €148-217 

Both  aspects  indicate  that  in  general  consumers  are  open  to  using  products  for  longer  and 
claim that they are willing to pay a comparable amount per expected year of life for this as the 
cost per year of the product. 

Finally, the survey reports that:  

83  Behavioural  Study  on  Consumers’  Engagement  in  the  Circular  Economy;  LE  Europe,  VVA  Europe,  Ipsos, 
ConPolicy and Trinomics; October 2018 

182 

 
 
 
‘A  majority  of  survey  respondents  attached  high  importance  to  product  durability.  Among 
these respondents,  the top reason was that durable products  would  save them money in  the 
long run.’  
Another analysis carried out for ING84 shows that in many (mainly EU) countries between 40 
and  70%  of  people  say  they  are  willing  to  increase  the  reuse  of  products  by  having  them 
repaired as indicated in Figure 70. The share shows a decreasing trend with per capita income. 
There is clearly a higher barrier to reusing products after repair than reusing an EPS when the 
original end-use product is no longer in use, but this nevertheless provides a useful indication 
of the proportion of the population that may be open to reuse EPS. 

Figure 70 - Relation between per capita income and openness to reuse of products after repair 

Conclusions 

The information gathered shows that even without any obligation, manufacturers are willing 
to offer a share of powered products without an EPS with the product. This share appears to 
be slowly increasing.  

For  this  unbundling  by  manufacturers  to  result  in  an  environmental  benefit  requires 
consumers  to  be  willing  to  reuse  EPS  from  one  product  to  another.  While  there  is  limited 
information about this, other evidence is available that suggests by analogy that there would 
be a substantial willing ness to do this. The main elements can be summarised as being: 

•  76% of consumers say they are inconvenienced by a multiplicity of EPS; 
•  depending on the product, between 30 and 69% of people want to use them till they 

fail; 

•  93% of people say they use products a long time;  
•  83% of consumers want the EU to set rules to prolong product lives; 
•  between  23%  and  67%  of  people  state  they  take  account  of  different  environmental 

aspects in their product purchases;  

•  consumers appear to be willing to pay for extra life from new product prices; 

84 https://think.ing.com/reports/circular-economy-rounding-up-the-costs-and-benefits/  

183 

 
 
 
 
 
•  consumers say they want more durable products to save money; 
•  between 40 and 70% of people are willing to increase their reuse of products. 

Taking  all  these  different  surveys  together  they  point  to  a  range  between  25%  and  75%  of 
consumers that appear to be keen to use products longer, take the environment into account in 
their actions and to prolong product lives to save money. 

The  reuse  of  EPS  would  increase  consumer  convenience,  save  money  and  lead  to 
environmental benefits without any effort by the consumer. These factors would suggest that 
a  reuse  rate  towards  the  higher  end  of  the  range  could  be  expected.  However,  an  added 
uncertainty  relates  to  how  much  longer  an  EPS  would  actually  function  for  if  it  is  reused. 
There is no real information on this since in the past EPS generally outlived the products they 
powered. It is most likely that the actual technical lifetime of EPS will depend both on their 
design and the duty cycle to which they are subject. In the absence of any detailed information 
it is taken as a working assumption that an EPS would be capable of functioning for twice as 
long  as  the  device  that  it  initially  powers.  This  does  not  seem  unreasonable  since 
manufacturers would have no reason to wish their EPS to fail quickly and because the main 
determinant of EPS lives seems to be the temperature which the electrolytic capacitors in the 
EPS will experience. 

In  view  of  this  analysis,  the  central  assumption  used  in  this  Impact  Assessment  is  that  the 
lives of EPS will be extended by 50% above the life they would have had powering the initial 
product. The upper and lower limits of the identified range are tested with a sensitivity test of 
half this rate or an increase of it by 50%. 

184 

 
 
 
 
ANNEX 17: DETAILED COMPLEMENTARY AND SUPPORTING 
INFORMATION 

USB-PD power curve (USB-IF) 

Figure 71 - USB-PD EPS output voltage and power 

In-line with the USB-PD 3.1 specifications85, EPS falling under the interoperability measure 
would  need  to  be  able  to  supply  standardised  fixed  voltages  demanded  by  the  specific  end-
devices.  Each  EPS  has  a  maximum  power  rating  which  determines  all  the  lower  fixed 
voltages which the EPS must be able to supply86. This is illustrated in Figure 71. Above 20V, 
the USB-PD specification requires the power supply to be able to deliver a minimum power 
as shown by the lower end of the bars, i.e. 100W for 28V output, 140W for 36V output and 
180W for 48V output.  

Vacuum cleaners 

A  number  of  handheld  vacuum  cleaners  was  analysed  regarding  their  EPS  (cf.  Figure  72). 
They  are  supplied  (charged)  with  fixed  voltages  between  15V  and  42V  and  a  maximum 
power  ranging  from  5W  to  35W.  Supplying  these  devices  with  USB-PD  power  supplies 
would require  for most  of  them more  expensive oversized high  power 100W or 140W EPS 

85 https://www.usb.org/usb-charger-pd. 

185 

 
 
 
 
 
 
 
 
operated  with  EPR-grade  e-marked  cables  necessary  for  voltages  above  20V.  To  avoid  the 
potentially expensive oversizing of certain EPS, is necessary for the interoperability measure 
to allow for exemptions in technically justified cases of high-voltage/low-power combinations 
falling outside the USB-PD range. 

Vacuum cleaner chargers (EPS)

R
E
W
O
P
R
E
G
R
A
H
C

40
35
30
25
20
15
10
5
0

0

10

20

30

40

50

CHARGER VOLTAGE

Figure 72 - Handheld vacuum cleaners' charging voltage and power (online data) 

Peak-power illustration 

Figure 73 - Peak power above the USB-PD maximum power limit (illustration provided by Apple) 

186 

 
 
 
 
 
 
 
 
 
Active PoE injectors 

Figure 74 - Outline of PoE with a midspan power over ethernet injector 

Scale of electricity savings as a proportion of the EED 2030 energy savings goals 

The Energy Efficiency Directive sets targets for energy savings through efficiency measures 
by 2030. It requires a reduction of energy consumption of at least 11.7 % in 2030 compared to 
the  2020  EU  Reference  Scenario  projections.  This  would  mean  that  the  EU’s  2030  final 
energy consumption should be no more than 763 Mtoe. Since this is an 11.7% reduction, the 
decrease is 101 Mtoe which equals 1174 TWh.  

Table 64 - PO electricity savings as proportion of EED final energy target 

The table above shows the estimated EPS share of EU electricity consumption in 2035, and 
the  expected  reduction  under  each  PO.  The  right-hand  column  indicates  the  share  that  the 
2035 electricity savings under the different POs would represent as a proportion of the overall 
2030 EED final energy target. 

187 

EPS share of EU electricityReduction in EPS share of 2035 EU electricity useEPS 2035 electricity savings as % of 2030 final energy targetBAU0.304%PO10.275%0.028%0.10%PO20.301%0.002%0.01%PO30.297%0.007%0.02%PO40.301%0.002%0.01%PO50.297%0.007%0.02%PO60.298%0.005%0.02%PO70.298%0.005%0.02%PO80.293%0.011%0.04%PO90.280%0.024%0.08% 
 
 
 
 
ANNEX 18: REFERENCES 

APPLIA  (2022):  Contribution 
https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13351-External-
power-supplies-ecodesign-information-requirements-review-/F3255604_en. 

to  call  for  evidence  on  external  power  supplies, 

Directive 2009/125/EC (2012): Directive 2009/125/EC of the European Parliament and of the 
Council  of  21  October  2009  establishing  a  framework  for  the  setting  of  ecodesign 
for  energy-related  products  (recast).  Ecodesign  Directive;  https://eur-
requirements 
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02009L0125-20121204. 

Directive  2014/35/EU  (2014):  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 
relevance).  Low  Voltage  Directive;  https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014L0035. 

(Text  with  EEA 

limits 

Ecodesign Impact Accounting (2021) https://op.europa.eu/en/publication-detail/-
/publication/392bc471-76ae-11ed-9887-01aa75ed71a1/language-en#share  

IA  Common  Charger  (2019):  Impact  assessment  study  on  common  chargers  of  portable 
devices,  European  Commission.  Directorate  General  for  Internal  Market.  Industry. 
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IA  Unbundling  (2021):  Impact  assessment  study  to  assess  unbundling  of  chargers:  final 
Industry, 
Internal  Market, 
report.  European  Commission.  Directorate  General 
Entrepreneurship and SME.; Economisti Associati, IPSOS, Trinomics, Fraunhofer. 

for 

Regulation  (EU)  2019/1782  (2019):  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  (Text  with  EEA  relevance),  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=uriserv%3AOJ.L_.2019.272.01.0095.01.ENG&toc=OJ%3AL%3A201
9%3A272%3ATOC#. 

TS  Wireless  Charging  (2021):  Technical  supporting  study  to  assess  the  status  of  wireless 
charging  technologies  used  for  mobile  phones  and  similar  portable  equipment  and  next 
expected  main  technological  developments:  deliverable  5  (D5)  :  final  report.  European 
Commission. Directorate General for Internal Market. Industry. Entrepreneurship and SMEs; 
Fraunhofer IZM. 

188