But this is a portable product. And the best looking/made one you have reviewed IMO.
The EU directives on SPL exposure and the attendant requirements to limit/monitor/record exposure appear very onerous for portable devices. Sony clearly takes it very seriously judging by the inbuilt controls (AVLS/cumulative exposure display etc). Limiting maximum continuous power in any circumstance that could result in hearing damage and the consequent legal ramifications could be massive for such a large company like Sony.
The same rules/guide lines probably don't apply to desktop products. The levels attainable in desktop product headphone amplification are utterly ridiculous and will surely result in similar requirements down the track. Having several watts on tap and large voltage swings are a recipe for a whole bunch of hearing damaged geeks in a decade or two.
Come to think of it, the loudest portable devices of the past were the original Sony Walkmans (cassette) in the early 1980s. They produced stupid high levels in their headphones. But the exposure period was shorter (one cassette at a time) or the batteries gave out! The CD walkman era products were more sensible in levels. But people can listen for hours and hours on modern portable devices and the maximum levels must be limited.
Indeed, but makes me wonder if there are any audio professionals consulted or included in the team of regulators. How is this treshold determined, when no headphone can generate the same SPL, and the numbers are all over the place. We can't be against safety, but how to fit the need of people that care about reproduction within this, I have no solution, but a device like that, is not like a smartphone, it better perform, and if tresholds are strictly set by audiologist with premises like "we can find a earbud that can generate more than 90 dB SPL at X Volts, so let's put a hard cap at X" Well the hobby of audiophile portable audio is dead. In cell phones it's pretty much impossible to have some dynamic headroom, and if you end up always cranking them up to hear something, I suspect some amount of dynamic compression/limiting. That's how most cell phones output sounds to my ears, compressed, but have no data to prove this, the measurements here, I believe, would not necessarily show this but I appreciate if someone can show me wrong, always. Basically, we don't necessary want more volume, but we want more headroom.
Now, back to this specific product, as you rightfully point out, it could be argued than in this case, well, Sony might only be guilty of... well being Sony. It's a bit unfair, but small companies do not have these limitations really, Hiby or A&K, or even FIIO, would not care, and rightfully so if they still want to have a market, if not there is no business for them period. Not only they are surely under the radar, even if they were on the radar, it's fair to think that regulators would simply accept that it's a niche market, their buyer make a responsible decision in choosing something with more power, and acknowledge that we can somehow trust them to care about their earing. So, for cell phones, I could agree and accept because the device was not bought for music first, and maybe, legally, an argument could be made that, well, I didn't know I was buying something that could blow my eardrums, now pay. Portable players/amps should be a different class of product, maybe include some mandatory warning, but let the enthousiasth have the option to enjoy the headphone that they tastefully chosen and allow them to ear the full dynamic of the recording. Now... maybe in the end I give this too much importance if Sony is the only DAP manufacturer to actually follow these regulations... I guess they can survive this. The small players would not.