Table of Contents

1.    Introduction: Political and legal context    

1.1.    Implications of the ecodesign framework    

1.2.    EU energy and climate objectives    

1.3.    The contribution of Ecodesign    

1.4.    Importance of the regulation under review    

1.5.    Sustainable development goals    

1.6.    Legal context of the impact assessment    

1.7.    Impact of the revision of the Radio Equipment Directive    

2.    Problem definition    

2.1.    What are the problems?    

2.2.    What are the problem drivers?    

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

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

3.    Why should the EU act?    

3.1.    Legal basis    

3.2.    Subsidiarity: Necessity of EU action    

3.3.    Subsidiarity: Added value of EU action    

4.    Objectives: What is to be achieved?    

4.1.    General objective    

4.2.    Specific objectives    

4.3.    Consideration of alternative objectives    

5.    What are the available policy options?    

5.1.    The intervention logic    

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

5.3.    The interactions between EPS efficiency, durability and interoperability    

5.4.    Description of the policy options (POs)    

5.5.    Policy Options matrix    

6.    What are the impacts of the policy options?    

6.1.    Business-as-Usual (BAU)    

6.2.    Economic impacts of the POs    

6.3.    Environmental impacts of the options    

6.4.    Social impacts    

6.5.    Impact on societal costs    

6.6.    Overview of the PO impacts    

7.    How do the options compare?    

7.1.    How the options are compared    

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

7.3.    Effectiveness and efficiency of options    

7.4.    Scoring the options    

7.5.    Ranking the options    

8.    Preferred option    

8.1.    Legal requirements    

8.2.    Main impacts    

8.3.    Verifying the missed environmental benefits of other options    

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

8.5.    REFIT    

8.6.    One-In One-Out    

8.7.    Concluding remarks    

9.    How will actual impacts be monitored and evaluated?    

Annex 1: Procedural information    

Annex 2: Stakeholder consultation (Synopsis report)    

Annex 3: Who is affected and how?    

Annex 4: Analytical methods    

Annex 5: The Ecodesign and Energy Labelling Framework    

Annex 6: Products in scope of the current EPS regulation    

Annex 7: Evaluation of Regulation (EU) 2019/1782 on Ecodesign requirements for External Power Supplies    

Annex 8: The SME test    

Annex 9: Competitiveness Check    

Annex 10: List of measures and preliminary assessment    

Annex 11: Discarded measures    

Annex 12: Selection of pollutants for analysis    

Annex 13: Sensitivity tests    

Annex 14: Additional impacts of the Policy Options    

Annex 15: Valuing consumer (In)Convenience    

Annex 16: Evidence underlying assumptions of extended interoperable EPS lifetimes    

Annex 17: Detailed complementary and supporting information    

Annex 18: References    

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.

1.2.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 Deal 2 to strengthen these objectives and as the cornerstone of its strategy to fulfil the United Nation’s 2030 Agenda for Sustainable Development 3 . In September 2020, it presented a Climate Target Plan (CTP) for 2030 4 , 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” package 5 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 reference 7 . The EED itself contains limited energy saving measures and in addition to Member State actions, additional measures at EU level are needed 8 . 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 Plan 9 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 reasons 10 . 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.

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 efficiency 11 . Market failures arise from the fact that many impacts and aspects of energy supply or resource use are not brought into market prices 12 . 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 Directive 13 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 Accounting 14 (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 2022-2024 15 , 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 growth 16 . 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.

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);

·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:

owireless chargers (R2),

oactive power over Ethernet injectors (R3), and

oexternal 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.

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 CPRICE 18 . 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.

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.

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.

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 efficiency 19  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.

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 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 charger 20 which is not USB-PD compliant and is therefore not usable with other end products..

The recently revised Batteries Regulation 21 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.

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.

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 APPLiA 22 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 Directive 23 (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 compliant 24 . 

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 standards according to specific sections of EN 55035. In addition, the practice of certain telecom operators 25 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 study 26  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 charging 27 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.

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 considerably 28 . The Qi charging technology dominates the current market, but new and proprietary technologies are under development. 29 The various technologies are not interoperable.

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 housing 30 . 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 V 31 . For many PoE injectors, no efficiency is 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.

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 2 Table 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.

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 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 MoU 32 , 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.

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.

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 saving 33 . 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 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.

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.

·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.

Table 3 - Matrix showing how the different measures address the review clause aspects and problem drivers

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.

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.

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.

Figure 8 - Interactions between interoperability, durability and energy

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.

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.

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.

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

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 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.

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.

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 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 . 

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.

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 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.

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.

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 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. 

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 .

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.

The Directive also sets a series of requirements in its Article 15(5) on functionality, health, safety and environment, affordability, competitiveness, proprietary technology and 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.

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.

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 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.

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.

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. 

Annexes

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:

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:

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.

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 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 the latest USB technologies enabling more 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.

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.

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 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 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 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 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.

Annex 3: Who is affected and how?

Practical implications of the initiative

The initiative will concern all of EU population 35 , 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 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.

Table 16 - Summary of costs and benefits

Table 17 - Overview of costs – Preferred option PO6

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

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 .

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 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

-Electricity costs

-Impacts of changes in electricity grid mixes in the EU

-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 .

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

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 .

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.

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.

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.

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.

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.

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.

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

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 27 below.

Table 27 - Fuel combustion per MWh electricity

Employment

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:

Table 28 - Employment intensity by turnover

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.

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 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 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.

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 .