I've always wondered what the reason for the volume cap was.
Some details in this discussion from 2012
https://www.head-fi.org/threads/the-eu-volume-cap-mystery.600111/post-8211599
In short, EU passed laws to protect people's hearing. This is a wrong use of law, impractical, and impossible, which I see as no different than passing a law on what/how much people can eat so they will not get obese. But regardless, a law it is.
But it is a mess, as mandating a specific decibel limit, without taking into consideration that different amps/headphones could need more or less power for the same decibel output. So manufacturers (large ones that have a lot of revenue that can be penalized) have implemented a cap, mostly with the goal to reduce the risk of large fines, and they err on the side of caution. The law itself is badly defined, as the DAP manufacturer has no way of knowing what headphone/earphone the user will use, so have no way to tell what the decibel output will be. So the implementation is often brute force, as the EU enforcement could be arbitrary, so companies choose not to take chances with the implementation. They will err on the side of too much, rather than not enough.
Another question people ask is why so many small DAP companies do not implement a volume cap. The general understanding is that they are too small (footprint/revenue) to be targeted by the EU for extra revenue, and they can always just pull out of the market at any time, if they have to. In addition, even the distribution network could be grey market, so they can say they are not officially releasing products into the EU.
People also ask why the manufacturer does not provide a way to defeat the volume cap, like with a setting, alternate Firmware, etc. The answer is obvious, of course. Any bypass provided by a manufacturer would absolutely be interpreted as breaking the law, and would leave the company open to punitive fines.
That this law is stupid, and badly/not thought out properly? Yes, it absolutely is. But anybody who tries to argue with the government will lose. First by spending a fortune on lawyers and courts, and then by forced product changes/recalls, and penalties.
That the EU passes many mandates, and regularly assesses large fines against corporates, should not be news to anybody. A quick search online will find many examples.
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