And as I said earlier, there are quite a few cases where the psu is top mounted, not on the bottom. This tends to make the psu the primary exhaust unless there's also a exhaust fan below, next to the cpu. So in effect, the psu sees the entire heat output of both cpu and gpu, possibly. Not a fan personally of that design, which was something to think about when Asus revealed its Ryzen cpu build that included a R7 1700x and gtx1070 in an mATX case with a top load psu and a single intake fan.
And while correct in stating its upto the user, that's only mostly true. It can depend on the case and the psu itself. I've seen plenty of older case styles where if you used a psu with a switch in back, the case frame would need to be modified since the mounting hole is off center or not large enough. Sometimes it's even a cutout for the power connection. So occasionally there are limitations as to psu orientation.
There still remains a considerable amount of ppl, especially on the indo-asian markets that are still using older FX cpus, with older amd cards like the 290 or 290x, so with summer heat, and no ac, where ambients can hit close to, if not over, 40°C on the outside of the case, adding in the cpu/gpu heat output on top of that just makes for a electronic oven. A fan down psu would make a lot of sense there, especially as the number 1 selling psu in those markets is the Corsair CX, which unfortunately isn't a 40°C unit. The old style anyways.
Never crossed my mind about the hybrid/eco being affected by orientation. Is that something that taken into consideration during design planning and settings choice? Or is it just a blanket number assigned, someone deciding 'oh, we'll kick the fan on at 35°C' etc?