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Hm, wireless headsets are usually limited by the manufacturer. And the maximum loundness is limited by law in some countries, but I'm not sure about the USA.

 

You don't have that problem with headphones with a 3.5mm jack because their loudness depends on the comination of the output power of the audio source and the sensitivity of the headphone.

Their sensitivity is usually on the package in dB SPL/mW.
High sensitivity headphones can get louder. I only use in-ear monitors, but I can say that the ones with over 120 dB can get very loud with my audio devices.

Or you can increase the output power with a headphone amp, but it would be weird to connect an amp to controllers like the DualShock 4...