Introduction
The EU Eco-Design Regulation (EU) 2025/2052, adopted in 2025 and enforceable from 2028, represents a fundamental shift in how Customer Premises Equipment (CPE) is powered. Unlike previous regulations, it explicitly addresses USB-C Power Delivery (PD), higher power levels, interoperability expectations, and efficiency performance across the entire operating load curve.
While USB-C PD is central to the EU’s long-term objectives around common chargers, reduced e-waste, and circular-economy goals, its application within always-on broadband and network CPE introduces clear technical and operational limitations.
Power Supplies Are Not Chargers
A critical clarification within the assessment is the distinction between USB-C chargers and CPE power supplies.
Power supplies are not chargers.
Although both may share the same USB-C connector and regulatory marking, their functional requirements differ fundamentally:
- Chargers are designed for battery-based consumer devices
- CPE power supplies must support continuous, 24/7 operation
- Broadband equipment exhibits different load profiles, peak current behaviour, and lifetime expectations
The regulation highlights the risk of end users substituting CPE power supplies with phone or laptop chargers, which are not designed for this application—leading to instability, non-compliance, and increased field issues.
USB-C PD Power Limits at Common CPE Voltages
Most deployed CPE platforms today are designed for 12V DC input, which creates immediate constraints under USB-C PD:
- USB-C PD without an e-marker cable is limited to 3A
- At 12V, this equates to a maximum of 36W
- Any 12V CPE requiring more than 36W therefore cannot operate safely or compliantly without:
- A 5A e-marked cable
- A custom USB-C PD power supply
This introduces additional sourcing, validation, and compliance complexity—particularly at scale.
Reluctance to Redesign CPE for Higher Voltages
The assessment identifies a strong industry reluctance to redesign CPE platforms to operate at 15V or 20V:
- Many existing CPE designs are fixed 12V architectures
- Redesigning internal power stages increases:
- Development cost
- Time-to-market
- Certification and validation effort
As a result, USB-C PD adoption does not automatically translate into higher-voltage CPE designs across the installed base.
Detachable USB-C Cables: A Compliance Risk
Eco-Design 2025/2052 mandates detachable USB-C output cables, introducing new risks for CPE:
- Replacing the supplied cable with an inferior or non-compliant cable may:
- Break regulatory compliance
- Cause voltage drop or thermal issues
- Multiple cable variants must be:
- Sourced
- Tested
- Qualified
This significantly increases the compliance and validation burden for both OEMs and operators.
Efficiency Across the Entire Load Curve
A defining requirement of Regulation 2025/2052 is its focus on:
- Ultra-low no-load and standby power
- High efficiency at light and partial loads
- A flattened efficiency curve, not just peak efficiency
Meeting this requirement demands:
- Optimised PWM IC low-load and burst-mode behaviour
- System-level efficiency tuning across all operating conditions
The assessment shows that standard designs lose efficiency margin at light load, while NetBit-optimised designs maintain efficiency compliance margin across the operating range.
USB-C Interoperability: A Policy Goal, Not a Guarantee
While USB-C interoperability is a key policy objective of the regulation, the assessment makes clear that interoperability is not automatic:
- Identical connectors do not guarantee identical electrical performance
- Chargers and CPE power supplies serve fundamentally different use cases
- End-user assumptions of universal compatibility introduce real operational risk
Interoperability under USB-C PD therefore requires application-specific design and qualification, not connector-level standardisation alone. To achieve genuine interoperability it would be necessary to standardise on a more detailed set of specifications including, as a minimum, switching frequency, ripple voltage and noise profile.
Operator and MSO Challenges
From an operator perspective, USB-C PD introduces several risks:
- End-user confusion between chargers and CPE power supplies
- Increased likelihood of customers swapping power supplies or cables
- Higher incidence of:
- Field failures
- Customer complaints
- Truck-rolls
Service centres will also require more sophisticated test equipment to correctly screen returned USB-C PD power supplies.
Legacy CPE and the Transition Challenge
A major concern highlighted in the assessment is the treatment of legacy CPE still in production beyond 2028:
- Large volumes of high-value CPE remain deployed with DC barrel inputs
- Forcing a full USB-C transition risks:
-
- Premature replacement of serviceable hardware
- Increased e-waste
- Unnecessary capital expenditure
One possible transition solution is a USB-C to DC barrel adapter featuring:
- Short captive DC lead
- Ensures use of PSU compatible with existing 12V CPE voltage bus architecture (PSUs with 9V, 15V, 20V would not be able to power the CPE)
This would enable:
- Extended product lifetime – continued CPE deployment beyond Dec 2028 for products too early in their lifecycle to make obsolete but too close to EOL to merit the resource and financial investment to completely redesign.
- A low-risk, low-cost, regulation-aligned migration path
USB-C PD PSU Design Options for CPE
The assessment outlines purpose-built USB-C PD PSUs for CPE applications, including 20W, 45W, and 60W variants with compact EU and UK housings and common PCB platforms.
These designs reinforce a central conclusion of the regulation assessment:
USB-C PD for CPE must be engineered as infrastructure power—not adapted consumer charging.
Final Takeaway
EU Eco-Design Regulation 2025/2052 does not just mandate USB-C PD as a simple replacement for existing CPE power architectures. Instead, it demands:
- Higher efficiency across all load conditions
- Reduced energy waste
- Longer product lifetimes
- Careful, application-specific implementation of USB-C PD
USB-C PD introduces real and documented limitations in CPE when applied without infrastructure-grade design discipline.
For broadband networks, power supplies are not accessories — they are part of the network.
