Based on the OHMs law. The lower the impedance the higher is the current delivery requirement. Even worse, demand for power (current delivery) grows exponentially with declining frequences. That is why the first victim for low impedance headphones when connected to and amp with power limitations is bass impact. RME on page 12 of it’s DAC FS manual clearly describes that the unit switches to “Extreme Power” mode for loads below 32 Ohms and able to deliver 1.5 Watts @ 32 Ohm. While I salute RME for advanced features like DC protection, automatic volume control for different loads, and current protection circuit, low impedance still puts an extra requirements and maintaining great SINAD results in that region is difficult. And few headphones - Dan Clark for example go down to 12 or 14 Ohms for Noire and Expanse respectively. On the other hand, there are plenty of very good headphones to choose from with impedance that put amps in their optimal power delivery regions. You have mentioned few great headphones (Focal Clear/Celestee and HifiMan 1000) - all are above 32 Ohms. Also, the fact that they can be driven "effortlessly" does not mean that you are getting the best out of them.