These plugs limit the usability of the EPS to one manufacturer’s equipment. This is not considered specific for one model, so the replacement parts exemption cannot be claimed here.
The provision in Article 1.2 f) reads:
'external power supplies placed on the market no later than 30 June 2015 as a service part or spare part for an identical external power supply which was placed on the market not later than one year after this Regulation has come into force, under the condition that the service part or spare part, or its packaging, clearly indicates the primary load product(s) for which the spare part or service part is intended to be used with.'
To be exempted in the sense of the service/spare part, the EPS needs a specification on the device itself or on the packing establishing for which specific product/model it can be used. It is not sufficiently specific that the proprietary plug limits the application to the product range of a specific manufacturer/brand.
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.