Recently, discussions about the EU’s need to unify charging standards have been frequently seen in the newspapers, and there are reports that they may force Apple to abandon Lighting. In response to these questions, the president of USBIF wrote a real-name letter to respond.
The following is the original text of the letter:
Allow me to introduce myself as Jeff Ravencraft, President and COO of the USB Implementers Forum (USB-IF). USB-IF is a non-profit organization that supports the development and adoption of USB technology as defined in the USB specification, promotes the development of high-quality compliant USB devices through identification and compliance programs, and reinforces the benefits and compliance of USB product quality. For more information, including the latest products and technical announcements, visit the USB-IF website: www.usb.org.
On behalf of USB-IF, I provide feedback to the European Commission’s current discussions on “universal chargers” and provide comments on legislation under consideration. For misunderstandings seen in discussions of USB technology and standards, I’ll start with the basics:
USB charging technology is mainly to achieve simple, plug-and-play charging, and to provide services to consumers based on the following two principles:
(1) Consumers just need to go through USB interoperability and know that charging will be simple (without having to know the technical details or the differences between USB technologies)
(2) For consumers, it is important to be able to view easily identifiable signs (including power ratings) to understand the functionality of the charger and the level of charging experience it can provide
USB Universal Charging Interoperability and Innovation: The USB specification for data, power delivery, cables, connectors, and adapters is defined to enable a fully interoperable end-to-end universal charging solution, spanning multiple product categories, while supporting products Innovation. For USB Type-C™ and USB Power Delivery, power-related data communication methods are standardized for charger-device interoperability, while allowing product design innovation (including the use of fixed wiring or USB Type-C connectivity in specific products) device cables) and battery charging (such as product-specific charging circuits and algorithms implemented within the device).
USB backward and forward compatibility supports innovation while contributing to long-term environmental and consumer benefits. The USB specification is designed to support different generations of USB technologies (protocols, cables, and connectors with adapters) that have been on the market for many years, some even decades, not only reducing e-waste but also giving Convenience for consumers: Consumers can continue to use their existing devices, chargers, accessories for the life of the product, while over time, as the industry adopts new USB technology, it can be based on product needs, features and Use Case Choose when to make a purchase or upgrade to a new technology. USB-IF is committed to supporting long-term interoperability, a key reason for the global adoption of USB technology as a universal charging solution.
USB cables/connectors including USB Type-C™ are not universal and cannot be used as a universal connection scheme. They are specifically defined to support the USB technology fully defined in the USB specification.
In the USB-IF’s assessment, the proposed legislation does not fully understand how the USB specification (and its future development) works and is expected to work, and as a result, issues of interoperability, functionality, confusion and controversy may arise that will not only make Negatively impacting consumer expectations that USB products “just work” will also damage the USB brand image, leading to consumer or market confusion about how USB technology works and which products are compliant with the USB specification, and likely to be marketed because of these issues lead to a series of disputes or lawsuits.
Specifically, the main concerns of USB-IF are as follows:
(1) The proposed legislation is limited to one generation of USB technology (and further limited to one version of the EN/IEC standard). This approach would be detrimental to the environment and consumers, as it ignores the long-term benefits of USB interoperability, which come naturally through the interoperability between different generations of USB technology, including the different generations of device connectors that are highlighted in the proposal market transition period.
The USB-IF specification is designed to support long-term forward/backward compatibility, where multiple generations of USB technologies interoperate over many years or decades, helping to reduce e-waste over the long term and protect consumer investments. USB interoperability supports a range of products produced by the industry (based on legacy specifications or the latest specifications), thereby increasing consumer product choice (from low-end, low-cost, to higher-end) and when to buy or upgrade to the latest USB technology. For reference, here are the initial USB-IF release dates for the various generations of USB technology that are interoperable in the current market:
USB 2.0 and USB Standard-A (2000), USB Micro-B (2001), USB 3.0 (2008), USB BC 1.2 (2010), USB 3.1 (2013), USB Type-C™ (2014), USB PD ( 2014), USB 3.2 (2017), USB4™ (2019) and USB PD 3.1 (2021).
The USB-IF carefully considers the timing of the release of the USB specification and the impact on the entire USB ecosystem (component suppliers, cable/accessory/end product manufacturers, distributors/retailers, consumers, etc.) support time. For USB cables and connectors, USB-IF will continue to support legacy specifications in testing and certification programs while maintaining market relevance. This benefits the long-term benefits of natural market technology transitions that would be undermined by proposals against using them until the natural market for non-USB-C connectors is eliminated.
(2) The European Commission points out that the proposed legislation can be quickly updated by reference to revised or newly developed USB standards. The USB-IF disagrees with this statement on the following grounds:
The USB standard is continuously updated through ECNs (Engineering Change Notifications), technical improvements, new features and specifications. In fact, the two standards cited in the EC proposal: EN IEC 6280-1-3:2021 and EN IEC 6280-1-2:2021, are both outdated. These standards are based on the USB-IF specification published in August 2019, with revisions published by the USB-IF in May 2021. The revision includes major updates to support up to 240W of power via USB Type-C™ cables and connectors.
Early adoption of USB refresh products began shortly after the release of the USB-IF, and was gradually adopted by the mass market. Conversely, there may be a significant time lag between the publication of a revision or new specification of USB-IF, and its submission to the IEC and adoption as an international standard, and then by CENELEC as an EN standard. Also, because the formal IEC standardization process takes time, the USB-IF will not submit all incremental revisions to the IEC until the next major update to the specification.
In addition, the USB-IF also noted that even after IEC and CENELEC publish revised versions or new USB standards, there will be a further time lag for the regulatory approval process to review and update proposed legislation.
(3) This proposal only focuses on certain aspects of the USB standard (eg, physical USB Type-C? receptacles, charging protocols only available above 15W). However, unless optional features are defined in the standard, the USB-IF standard will be implemented as a whole to ensure universal charging interoperability and backward compatibility. Given that the USB-IF standard is a monolithic document that exists within a larger framework of other standards, any requirements derived from these standards must remain within their complete context to be valid.
The USB-C standard specifies interoperability requirements between power supplies (such as chargers) and devices, including: data, charging protocols, and cable specifications for all power levels supported by the standard; specifications for USB-C physical connectors and cables (USB-C to USB-C or other USB connectors, USB-C to other industry-defined or product-specific connectors); and support for legacy USB data, charging protocols, and connector adapters for backward compatibility.
Neither the USB Type-C™ Cable and Connector Specification nor the USB Power Delivery Specification are separate documents; they not only complement each other, but also complement the USB 2.0, USB 3.2, and USB4™ specifications.
In addition, these specifications contain normative references to carefully considered other standards that specify requirements for safety, electromagnetic compatibility, energy efficiency, safety and interoperability.
4) The proposed legislation includes an explicit statement to allow other charging protocols over USB Type-C. As stated in the proposal, how does the European Commission intend to “ensure that any additional charging protocols allow for the full functionality of USB Power Delivery”?
This proposal specifies the use of products that do not comply with the USB specification and therefore cannot pass the USB-IF compliance program. USB-IF does not certify products with proprietary charging protocols (not allowed in the USB Type-C standard) because USB-IF cannot verify, guarantee that proprietary protocols (which may change, evolve over time) will not Interfere, cause interoperability issues, affect secure operations, affect the consumer experience, or cause consumers to have difficulty understanding the use of USB technology beyond their intended scope.
There is also a legal risk that the proposal could confuse or mislead manufacturers. Among other things, through partial agreements within the USB ecosystem, licenses under certain intellectual property rights are granted for use in products that conform to the USB specification. Since these protocols do not apply to products that do not comply with the USB specification, including those expressly specified or permitted in the proposed legislation, this proposal could inadvertently expose manufacturers to additional legal risks.
(5) At present, it is not clear whether the European Commission intends to develop some kind of conformity testing or certification scheme for “EU universal chargers” in addition to the requirements of the proposed legislation. USB-IF is concerned that potential conflicts between such EU programs and USB-IF’s trademarks, logos, and certification programs will lead to confusion in the marketplace for consumers, industry adopters, operators, or retailers.
USB-IF continues to focus on improving and simplifying device, cable, and charger labeling by simplifying identification to only identify the performance (data rate) or power (total watts) of certified products given by USB-IF, making it easy for consumers to understand product functionality without having to understand USB technology differences.
As the USB standard continues to evolve, USB-IF also supports the latest USB technology for the benefit of consumers by continually evolving, improving, and simplifying our logos and labels. Guidelines for using the USB-IF logo can be found at www.usb.org. Note: The current USB-IF logo usage guidelines do not include the new USB4™ performance and cable logos, as these logos have just been released, and our guide will include these when updated this quarter. The proposal also includes requirements for device labeling and describes the USB power supply capability through the text “USB PD fast charging”. However, unlike the term “watts” which is an unequivocal indicator of a device’s capability, the term “fast” is not a quantitative term, but a marketing term, and therefore should not be used.
I’m excited to have the opportunity to explore how to address these issues.
Recently, discussions about the EU’s need to unify charging standards have been frequently seen in the newspapers, and there are reports that they may force Apple to abandon Lighting. In response to these questions, the president of USBIF wrote a real-name letter to respond.
The following is the original text of the letter:
Allow me to introduce myself as Jeff Ravencraft, President and COO of the USB Implementers Forum (USB-IF). USB-IF is a non-profit organization that supports the development and adoption of USB technology as defined in the USB specification, promotes the development of high-quality compliant USB devices through identification and compliance programs, and reinforces the benefits and compliance of USB product quality. For more information, including the latest products and technical announcements, visit the USB-IF website: www.usb.org.
On behalf of USB-IF, I provide feedback to the European Commission’s current discussions on “universal chargers” and provide comments on legislation under consideration. For misunderstandings seen in discussions of USB technology and standards, I’ll start with the basics:
USB charging technology is mainly to achieve simple, plug-and-play charging, and to provide services to consumers based on the following two principles:
(1) Consumers just need to go through USB interoperability and know that charging will be simple (without having to know the technical details or the differences between USB technologies)
(2) For consumers, it is important to be able to view easily identifiable signs (including power ratings) to understand the functionality of the charger and the level of charging experience it can provide
USB Universal Charging Interoperability and Innovation: The USB specification for data, power delivery, cables, connectors, and adapters is defined to enable a fully interoperable end-to-end universal charging solution, spanning multiple product categories, while supporting products Innovation. For USB Type-C™ and USB Power Delivery, power-related data communication methods are standardized for charger-device interoperability, while allowing product design innovation (including the use of fixed wiring or USB Type-C connectivity in specific products) device cables) and battery charging (such as product-specific charging circuits and algorithms implemented within the device).
USB backward and forward compatibility supports innovation while contributing to long-term environmental and consumer benefits. The USB specification is designed to support different generations of USB technologies (protocols, cables, and connectors with adapters) that have been on the market for many years, some even decades, not only reducing e-waste but also giving Convenience for consumers: Consumers can continue to use their existing devices, chargers, accessories for the life of the product, while over time, as the industry adopts new USB technology, it can be based on product needs, features and Use Case Choose when to make a purchase or upgrade to a new technology. USB-IF is committed to supporting long-term interoperability, a key reason for the global adoption of USB technology as a universal charging solution.
USB cables/connectors including USB Type-C™ are not universal and cannot be used as a universal connection scheme. They are specifically defined to support the USB technology fully defined in the USB specification.
In the USB-IF’s assessment, the proposed legislation does not fully understand how the USB specification (and its future development) works and is expected to work, and as a result, issues of interoperability, functionality, confusion and controversy may arise that will not only make Negatively impacting consumer expectations that USB products “just work” will also damage the USB brand image, leading to consumer or market confusion about how USB technology works and which products are compliant with the USB specification, and likely to be marketed because of these issues lead to a series of disputes or lawsuits.
Specifically, the main concerns of USB-IF are as follows:
(1) The proposed legislation is limited to one generation of USB technology (and further limited to one version of the EN/IEC standard). This approach would be detrimental to the environment and consumers, as it ignores the long-term benefits of USB interoperability, which come naturally through the interoperability between different generations of USB technology, including the different generations of device connectors that are highlighted in the proposal market transition period.
The USB-IF specification is designed to support long-term forward/backward compatibility, where multiple generations of USB technologies interoperate over many years or decades, helping to reduce e-waste over the long term and protect consumer investments. USB interoperability supports a range of products produced by the industry (based on legacy specifications or the latest specifications), thereby increasing consumer product choice (from low-end, low-cost, to higher-end) and when to buy or upgrade to the latest USB technology. For reference, here are the initial USB-IF release dates for the various generations of USB technology that are interoperable in the current market:
USB 2.0 and USB Standard-A (2000), USB Micro-B (2001), USB 3.0 (2008), USB BC 1.2 (2010), USB 3.1 (2013), USB Type-C™ (2014), USB PD ( 2014), USB 3.2 (2017), USB4™ (2019) and USB PD 3.1 (2021).
The USB-IF carefully considers the timing of the release of the USB specification and the impact on the entire USB ecosystem (component suppliers, cable/accessory/end product manufacturers, distributors/retailers, consumers, etc.) support time. For USB cables and connectors, USB-IF will continue to support legacy specifications in testing and certification programs while maintaining market relevance. This benefits the long-term benefits of natural market technology transitions that would be undermined by proposals against using them until the natural market for non-USB-C connectors is eliminated.
(2) The European Commission points out that the proposed legislation can be quickly updated by reference to revised or newly developed USB standards. The USB-IF disagrees with this statement on the following grounds:
The USB standard is continuously updated through ECNs (Engineering Change Notifications), technical improvements, new features and specifications. In fact, the two standards cited in the EC proposal: EN IEC 6280-1-3:2021 and EN IEC 6280-1-2:2021, are both outdated. These standards are based on the USB-IF specification published in August 2019, with revisions published by the USB-IF in May 2021. The revision includes major updates to support up to 240W of power via USB Type-C™ cables and connectors.
Early adoption of USB refresh products began shortly after the release of the USB-IF, and was gradually adopted by the mass market. Conversely, there may be a significant time lag between the publication of a revision or new specification of USB-IF, and its submission to the IEC and adoption as an international standard, and then by CENELEC as an EN standard. Also, because the formal IEC standardization process takes time, the USB-IF will not submit all incremental revisions to the IEC until the next major update to the specification.
In addition, the USB-IF also noted that even after IEC and CENELEC publish revised versions or new USB standards, there will be a further time lag for the regulatory approval process to review and update proposed legislation.
(3) This proposal only focuses on certain aspects of the USB standard (eg, physical USB Type-C? receptacles, charging protocols only available above 15W). However, unless optional features are defined in the standard, the USB-IF standard will be implemented as a whole to ensure universal charging interoperability and backward compatibility. Given that the USB-IF standard is a monolithic document that exists within a larger framework of other standards, any requirements derived from these standards must remain within their complete context to be valid.
The USB-C standard specifies interoperability requirements between power supplies (such as chargers) and devices, including: data, charging protocols, and cable specifications for all power levels supported by the standard; specifications for USB-C physical connectors and cables (USB-C to USB-C or other USB connectors, USB-C to other industry-defined or product-specific connectors); and support for legacy USB data, charging protocols, and connector adapters for backward compatibility.
Neither the USB Type-C™ Cable and Connector Specification nor the USB Power Delivery Specification are separate documents; they not only complement each other, but also complement the USB 2.0, USB 3.2, and USB4™ specifications.
In addition, these specifications contain normative references to carefully considered other standards that specify requirements for safety, electromagnetic compatibility, energy efficiency, safety and interoperability.
4) The proposed legislation includes an explicit statement to allow other charging protocols over USB Type-C. As stated in the proposal, how does the European Commission intend to “ensure that any additional charging protocols allow for the full functionality of USB Power Delivery”?
This proposal specifies the use of products that do not comply with the USB specification and therefore cannot pass the USB-IF compliance program. USB-IF does not certify products with proprietary charging protocols (not allowed in the USB Type-C standard) because USB-IF cannot verify, guarantee that proprietary protocols (which may change, evolve over time) will not Interfere, cause interoperability issues, affect secure operations, affect the consumer experience, or cause consumers to have difficulty understanding the use of USB technology beyond their intended scope.
There is also a legal risk that the proposal could confuse or mislead manufacturers. Among other things, through partial agreements within the USB ecosystem, licenses under certain intellectual property rights are granted for use in products that conform to the USB specification. Since these protocols do not apply to products that do not comply with the USB specification, including those expressly specified or permitted in the proposed legislation, this proposal could inadvertently expose manufacturers to additional legal risks.
(5) At present, it is not clear whether the European Commission intends to develop some kind of conformity testing or certification scheme for “EU universal chargers” in addition to the requirements of the proposed legislation. USB-IF is concerned that potential conflicts between such EU programs and USB-IF’s trademarks, logos, and certification programs will lead to confusion in the marketplace for consumers, industry adopters, operators, or retailers.
USB-IF continues to focus on improving and simplifying device, cable, and charger labeling by simplifying identification to only identify the performance (data rate) or power (total watts) of certified products given by USB-IF, making it easy for consumers to understand product functionality without having to understand USB technology differences.
As the USB standard continues to evolve, USB-IF also supports the latest USB technology for the benefit of consumers by continually evolving, improving, and simplifying our logos and labels. Guidelines for using the USB-IF logo can be found at www.usb.org. Note: The current USB-IF logo usage guidelines do not include the new USB4™ performance and cable logos, as these logos have just been released, and our guide will include these when updated this quarter. The proposal also includes requirements for device labeling and describes the USB power supply capability through the text “USB PD fast charging”. However, unlike the term “watts” which is an unequivocal indicator of a device’s capability, the term “fast” is not a quantitative term, but a marketing term, and therefore should not be used.
I’m excited to have the opportunity to explore how to address these issues.
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