According to Point 3(c)(1) of Annex II to Regulation 2025/2052 an AC-DC EPS is not required to be an interoperable EPS if it it has a nameplate output power greater than 100 W.
What is the meaning of the parameter “nameplate output power”, what is it used for and how should this 100 W threshold be interpreted for different types of EPS, including adaptive ones?
The “nameplate output power” (Pout) is defined in Point (18) of Article 2 of the Regulation as: “any output power of the EPS as provided on the EPS nameplate pursuant to point 5(a) of Annex II to this Regulation, or displayed in Table 7, ‘Product information’, pursuant to point 5(g) of the same Annex;”
Practically it is any power value provided by the manufacturer on the EPS nameplate (point 5(a) of Annex II to the Regulation) or in the Product Information Sheet (point 5(g)) according to the corresponding requirements in Table 6 and Table 7 respectively.
Note that the Regulation requires that the nameplate power is the product of declared nameplate output voltage and nameplate output current. Several requirements of the Regulation refer to these declared nameplate values. For example, the Regulation has introduced a power output performance requirement, limiting the difference between the nameplate output voltage and output voltage determined under load and declared in Table 8.
For conventional non-adaptive fixed voltage EPS there is normally one single nameplate voltage/current/power value to be provided for a power output, for example 12V/3A/36W.
Adaptive EPS provide different fixed output voltages, so there is more than one nameplate voltage/current/power for each output. For example a single port 30W USB-PD EPS could have the following nameplate parameters: 5V/3A/15W, 9V/2A/18W, 15V/2A/30W.
For adaptive EPS with multiple ports the nameplate voltage/current/power must be in addition provided for the following conditions:
- for each single power output (meaning operated individually) at each fixed output voltage, like for example:
- Output 1: 5V/3A/15W, 9V/2A/18W, 15V/2A/30W, where 30W is implicitly the maximum nameplate output power for Output 1
- Output 2: 5V/3A/15W, 9V/3A/27W, 15V/3A/45W, where 45W is implicitly the maximum nameplate output power for Output 2
- Output 3: 5V/3A/15W, 9V/3A/27W, 15V/3A/45W, where 45W is implicitly the maximum nameplate output power for Output 3
- for each set of shared capacity ports: the maximum combined nameplate output power together with corresponding output voltage and current for each port, like for example
- if Output 2 and Output 3 are shared capacity ports:
- Output 2 + Output 3: 30W + 30W = 60W maximum combined
- Output 2: 15V/2A/30W
- Output 3: 15V/2A/30W
- the “total maximum output power” defined as “the maximum power that can be supplied by any combination or subset of the power outputs of an EPS operated simultaneously”, like for example,
- Output 1 + Output 2 + Output 3: 30W + 30W + 30W = 90W total maximum output power
- if Output 2 and Output 3 are shared capacity ports:
An EPS which has a nameplate output power higher than 100W is exempt from the interoperability requirements.
For example, a conventional fixed voltage 15V/120W EPS is not subject to interoperability requirements and can be placed on the market.
For an adaptive EPS the criterion applies to any nameplate output power, including a single port maximum power, the maximum combined nameplate output power of a set of shared capacity ports, or the “total maximum output power”.
In certain cases, adaptive EPS with multiple ports are therefore exempted from interoperability requirements, although each single port maximum power is below 100W.
This would for example apply to an EPS with only USB-A ports of 12W and total power above 100W, or to an EPS with a combination of USB Type-C and USB-A ports, each below 100W but with a total power above 100W, or with a combined power of shared capacity ports above 100W.
In conclusion, the current provision allows to exempt from the interoperability requirements EPS products not only with an output power per port above 100 W but also on the basis of the total maximum output power or the combined power of shared capacity ports being above 100W.
Note however that this exemption was introduced in response to concerns raised by the industry (registered under the reference Ares(2023)1912518) regarding the novelty and potential immaturity of the so called USB-PD Extended Power Range (i.e. 100W - 240W). This Extended Power Range is however relevant for an individual port, and not for the total power or the combined power of shared capacity ones. In this respect, considering that the intention of the Regulation was therefore to exempt from the interoperability requirement only such EPS where the nameplate output power of a single port is greater than 100W, the Commission services are considering to put forward a legal amendment (without prejudice of the Commission’s and the legislator’s positions) to align the legal text of Regulation 2025/2052 with the original intention (i.e. to exempt only products with an output power per single port above 100 W and NOT on the basis of the total maximum output power or the combined power of shared capacity ports).
Disclaimer: Please note that the European Commission cannot provide a legally binding interpretation of the EU legislation, as this is the sole competence of the European Court of Justice. Any remarks from the European Commission services are without prejudice to the position the Commission might take should related cases arise in a procedure before the Court of Justice.