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U.S. DOE Level VI is a mandatory federal energy-conservation standard for covered external power supplies sold in the United States. EU Code of Conduct Version 5, Tier 2 is a voluntary efficiency benchmark, not an EU law. For covered products placed on the EU market, the current binding ecodesign framework is Regulation (EU) 2019/1782. Meeting one regime does not automatically establish compliance with another: product classification, test conditions and documentation all matter.
What the three names mean
“Power adapter” is a familiar consumer term; regulations generally use external power supply (EPS). In general, an EPS converts mains electricity to lower-voltage AC or DC, powers a separate primary-load product, and is housed separately from it. The EU rule covers qualifying EPSs with nameplate output power up to 250 W when intended for specified household and office equipment. Not every charger, converter or laptop power brick necessarily falls into the same legal category.
| Program or rule | Geography | Status | What it does |
|---|---|---|---|
| DOE Level VI / federal EPS standards | United States | Mandatory for covered products | Sets energy-conservation requirements and test and compliance obligations. |
| EU Code of Conduct Version 5, Tier 2 | Voluntary benchmark | Not binding EU law | Provides a higher-efficiency comparison target used in DOE analysis. |
| Regulation (EU) 2019/1782 | European Union | Binding ecodesign regulation for covered EPSs | Sets market requirements including efficiency, no-load consumption, information and conformity obligations. |
DOE describes the CoC Tier 2 program as proposed but never implemented as binding EU regulation, while using its thresholds for analysis (DOE external-power-supply rulemaking). “CoC Tier 2” is therefore not a certification mark, CE mark or substitute for EU conformity obligations.
Which requirements apply in each market?
United States: DOE Level VI
Covered external power supplies must meet the applicable standards in 10 CFR 430.32(w) and be tested under Appendix Z to Subpart B of Part 430. Certification, reporting, sampling, record retention and enforcement requirements are addressed in Part 429. The DOE page summarizes the standards and compliance framework; manufacturers should check the current regulations and the applicable product classification rather than relying on a generic “Level VI” claim.
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Level VI is a federal energy-conservation compliance regime, not a global approval. It does not by itself demonstrate EU ecodesign compliance, CE conformity, electrical safety, EMC or compliance with other market-specific rules. State requirements and the extent of federal preemption are legal questions that should be assessed for the product and market in question, not inferred from a Level VI label.
European Union: binding ecodesign requirements
Regulation (EU) 2019/1782 has applied since April 1, 2020, replacing the earlier Regulation (EC) No 278/2009 for its covered product category. It applies to qualifying EPSs placed on the EU market or put into service and sets active-efficiency and no-load limits, measurement methods, information requirements, conformity provisions and market-surveillance procedures. See the European Commission’s EPS overview and the full regulation.
CoC Tier 2: an engineering target, not market authorization
Use “EU Code of Conduct Version 5, Tier 2” when referring to this benchmark. It can help set a more ambitious efficiency target, but the claim should identify the version and test basis. A product described as CoC Tier 2 compliant is not thereby proven to satisfy Regulation 2019/1782 or any U.S. requirement.
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The EU rule’s scope depends on the product’s function and intended use, not just its wattage. The regulation defines covered products and lists exclusions including voltage converters, uninterruptible power supplies, battery chargers without a power-supply function, lighting converters, external power supplies for medical devices, active Power over Ethernet injectors, docking stations for autonomous appliances and certain qualifying spare or service parts. See the regulation text. U.S. scope and exclusions must be checked separately in the current DOE rules; an EU exclusion does not automatically apply in the United States.
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Before comparing thresholds, identify whether the unit is AC-to-DC or AC-to-AC; basic- or low-voltage; single-output or multiple-voltage-output; fixed or adaptive; its rated output power; and the separate device it is intended to power. Battery chargers in particular are not automatically included or excluded: function and regulatory definition control. Products above 250 W are outside the current EU EPS definition described here, but that does not establish that no other EU requirements apply.
Efficiency and no-load limits: the baseline AC-to-DC comparison
The following figures reproduce DOE’s comparison for AC-to-DC basic-voltage EPSs. Efficiency is expressed as a decimal; output power is in watts; ln means natural logarithm. The CoC figures are Version 5 Tier 2 benchmark values, not binding EU legal limits. For each row, use the formula or limit matching the product’s output-power range.
| Nameplate output power | DOE Level VI minimum average active efficiency | DOE maximum no-load power | CoC Tier 2 minimum average active efficiency | CoC maximum no-load power |
|---|---|---|---|---|
| Pout ≤ 1 W | 0.5 × Pout + 0.160 | 0.100 W | 0.5 × Pout + 0.169 | 0.075 W |
| 1 W < Pout ≤ 49 W | 0.071 × ln(Pout) − 0.0014 × Pout + 0.67 | 0.100 W | 0.071 × ln(Pout) − 0.00115 × Pout + 0.67 | 0.075 W |
| 49 W < Pout ≤ 250 W | 0.880 | 0.210 W | 0.890 | 0.150 W |
| Pout > 250 W | 0.875 | 0.500 W | 0.890 | 0.150 W |
Source: DOE’s comparison of current standards and the CoC Tier 2 level. The last row is part of that comparison; it does not extend the EU rule’s up-to-250-W scope.
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- From above 1 W through 49 W, the CoC formula’s output-power coefficient is less negative, with a modestly higher target across that range.
- Above 49 W, the CoC basic-voltage target is 89.0% versus DOE’s 88.0% through 250 W; above 250 W the comparison is 89.0% versus 87.5%.
- The CoC no-load limit is 75 mW through 49 W, compared with DOE’s 100 mW. Above 49 W, the comparison is 150 mW for CoC versus 210 mW through 250 W under DOE.
These differences do not support a universal claim that CoC is a fixed percentage stricter for every adapter. The applicable class and test conditions change the comparison.
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Other product classes do not share one threshold table
AC-to-DC low-voltage EPSs
For low-voltage AC-to-DC products, DOE’s comparison gives these values:
| Nameplate output power | DOE Level VI efficiency | DOE no-load | CoC Tier 2 efficiency | CoC no-load |
|---|---|---|---|---|
| Pout ≤ 1 W | 0.517 × Pout + 0.087 | 0.100 W | 0.517 × Pout + 0.091 | 0.075 W |
| 1 W < Pout ≤ 49 W | 0.0834 × ln(Pout) − 0.0014 × Pout + 0.609 | 0.100 W | 0.0834 × ln(Pout) − 0.0011 × Pout + 0.609 | 0.075 W |
| 49 W < Pout ≤ 250 W | 0.870 | 0.210 W | 0.880 | 0.150 W |
| Pout > 250 W | 0.875 | 0.500 W | 0.880 | 0.150 W |
As with the preceding table, these are DOE’s comparison values, not a substitute for the governing rule or test procedure (DOE rulemaking).
AC-to-AC EPSs
AC-to-AC adapters have a different classification and no-load allowance, so the AC-to-DC table should not be applied to them. In DOE’s comparison, basic-voltage AC-to-AC EPSs up to 250 W have no-load limits of 0.210 W for DOE Level VI and 0.185 W for CoC Tier 2. Above 49 W, the cited average-efficiency targets are 88.0% and 89.0%, respectively. The DOE comparison also lists different CoC no-load values for low-voltage AC-to-AC products; do not infer those values from the basic-voltage class. See the class-specific DOE comparison and verify the current governing requirements before testing.
Multiple-voltage-output products
DOE states that its analysis found no equivalent EU CoC Tier 2 standards for multiple-voltage EPSs and therefore used a different, market-pass-rate-based efficiency level in its analysis. CoC Tier 2 should not be represented as a universal benchmark for a multiple-output adapter.
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Why a test result may not transfer between regimes
Input voltage and frequency
DOE’s analysis notes that products designed for 115 V AC typically show marginally lower active-mode efficiency than those designed for 230 V AC. A result measured at one voltage is not automatically interchangeable with a result at the other. For a global design, record the voltage and frequency used for each result and test at the conditions required by each applicable procedure.
Average active efficiency is not one-load efficiency
Active-mode efficiency is assessed at prescribed load points and calculated as an average; it is not the efficiency at whichever load is most favorable. No-load consumption is a separate measurement, taken without the primary load connected. Low-load performance, output settings and adaptive operation can also affect the result. DOE’s rulemaking notes that the CoC used a measurement and target at the 10% loading level, so test methods and load points must be identified when comparing figures.
Test report versus compliance file
For U.S. compliance, a non-equivalent private-lab test or marketing claim is not a substitute for the DOE procedure and applicable certification requirements. Consult 10 CFR Part 430 and Part 429. For the EU, test results are part of a broader set of measurement, conformity, information and technical-documentation duties under Regulation 2019/1782. A laboratory report alone does not necessarily establish full market compliance.
A practical compliance workflow for manufacturers and importers
- Identify the market. Determine where the adapter will be manufactured or distributed, placed on the market, or supplied as a service part. “Global adapter” is not a regulatory category.
- Classify the product. Document AC-DC or AC-AC conversion, output voltage and current, rated power, output count, fixed or adaptive behavior, intended primary-load equipment, and any potentially relevant exclusion.
- Select each applicable rule and test method. For the U.S., check the current 10 CFR 430.32(w), Appendix Z and Part 429. For the EU regime currently applicable, use Regulation 2019/1782 and its Annex II measurement and efficiency requirements.
- Write the test plan before testing. Specify input voltage and frequency, ambient conditions, no-load measurement, required load points, output settings, stabilization, instrument accuracy, sample count, calculation method and declared values.
- Assess each threshold with margin. Compare U.S. results with DOE requirements and EU results with the binding ecodesign rule. CoC Tier 2 may be an additional design target. Allow for production variation and differing test conditions rather than designing to a nominal threshold alone.
- Build market-specific evidence. Maintain the required test and certification records, product identification, ratings and information, and technical documentation. Depending on the regime and product, the file may also need schematics, critical-component data, model-family rationale, production-control evidence and change records. Confirm exact obligations against the applicable rule or with a qualified compliance professional.
Design and sourcing implications
Active efficiency and no-load power need separate attention
Improving loaded efficiency can involve transformer and switching-stage design, lower-loss semiconductors, synchronous rectification, improved control or other component changes. No-load consumption can remain too high even when active efficiency is strong. Control-IC quiescent current, bleeder resistors, EMI-filter losses, feedback, startup and sensing circuits, auxiliary rails and always-on USB-C or adaptive-protocol electronics can all contribute. A no-load redesign may therefore differ from a full-load efficiency redesign.
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One hardware platform may still need separate compliance work
A dual-market design can reduce hardware variants, but it does not remove market-specific testing, records, declarations, labels, plug and cord choices, or other applicable safety, EMC, radio, battery and product requirements. Output voltage, conversion type, output count and intended use can matter as much as wattage. CoC Tier 2 can be useful when an OEM wants a high-efficiency procurement target or additional design margin, but it cannot serve as a legal shortcut.
What to request from an adapter supplier
- Exact model number, hardware revision and rated output—not a generic family claim.
- Model-specific DOE compliance evidence, where U.S. requirements apply, and evidence addressing EU ecodesign where the product is sold in the EU.
- Test method and revision, test voltage and frequency, no-load result, active-efficiency results and the laboratory that performed the work.
- Whether the report covers the exact shipped configuration, including cable, plug and adaptive features.
- EU technical-documentation availability and any required certification or registration records for the relevant market.
- Change-control commitments covering components, firmware, manufacturing site and model revisions that could affect compliance.
For a small importer or a one-off product, an appropriately scoped external laboratory engagement may be more practical than buying precision power-analysis equipment. Ask the lab to confirm in writing that its scope includes the applicable DOE Appendix Z or EU ecodesign efficiency work; a general safety test package may not include either.
EU rule changes to watch in 2026
The European Commission product page says Regulation 2019/1782 will be replaced by Regulation (EU) 2025/2052 and gives a date of January 1, 2028. The EUR-Lex summary describes repeal of Regulation 2019/1782 with effect from December 14, 2028. Those dates should not be treated as interchangeable: application and repeal provisions can differ. The operative text and transitional provisions of Regulation 2025/2052 should be checked for the product and date at issue before relying on either date. See the Commission EPS page and the EUR-Lex summary. The incoming regime is described as updating requirements, including scope, interoperability, information and transitional treatment for certain spare parts.
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Quick Recap
Quick decision guide
- U.S. only: assess whether the product is covered, then use the applicable DOE standard, Appendix Z test procedure and Part 429 compliance obligations.
- EU only: determine whether it is a covered EPS, then assess Regulation 2019/1782 plus other applicable EU product obligations.
- U.S. and EU: classify and document against both legal regimes; do not assume one test result or label proves both.
- Premium efficiency goal: use CoC Version 5 Tier 2 as a clearly identified voluntary benchmark where the product class has comparable values, not as proof of legal access.
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