You don’t need to put the AirPods Max in its case to put it in a low power state
The AirPods Max are unique headphones, not just because of the way they look but also because of its features and how they work.
One unique aspect of it is how it doesn’t have a power button. This has led to confusion as to how the AirPods Max conserve battery.
It was believed that you had to put the AirPods Max into its case for it to enter its ultra-low-power state but Apple has now clarified that this is not true.
In an updated Apple Support Document, it states:
If you set your AirPods Max down and leave them stationary for 5 minutes, they go into a low power mode to preserve battery charge. After 72 stationary hours out of the Smart Case, your AirPods Max go into a lower power mode that turns off Bluetooth and Find My to preserve battery charge further.
If you put your AirPods Max in the Smart Case when you’re not using them, they go into a low power mode immediately to preserve battery charge. After 18 hours in the Smart Case, your AirPods Max go into an ultra-low power mode that turns off Bluetooth and Find My and maximizes battery life.
This explains why I found no difference in battery conservation when I left the AirPods Max out of its case versus when I left it in the case.