Our approach to substance management

Our restricted substances specification provides details about which substances are not allowed in our products, packaging, and supplier manufacturing operations. Microsoft restricted substances are identified based on legal requirements, the precautionary principle, and a scientific approach. When we have concern over a chemical’s potential for severe or irreversible damage to health or the environment, we believe actions should be taken to gather and assess additional data. Such investigations may lead to voluntary restrictions that go beyond legal requirements.

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Microsoft has created several environmental compliance specifications to inform suppliers of our restricted substance requirements and to establish documentation controls for demonstrating conformance with such requirements as follows:

Microsoft Restricted Substances for Hardware Products Specification - H00594

This document includes our restrictions for substances and chemicals that may be contained in our hardware products, packaging, or used during the manufacturing of our products.

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Restricted Substances Control System for Hardware Products - H00642

This document contains the documentation requirements that suppliers must provide to demonstrate their conformance to H00594. All suppliers are required to provide full material declarations and other documentation to ensure parts and products supplied to Microsoft meet the requirements of H00594. Full material declarations allow us to respond swiftly if new concerns arise about any substance, or if the regulatory landscape expands beyond the current substance restrictions contained in H00594.

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These specifications require that all parts, components, products, and packaging supplied to Microsoft meet global legal and Microsoft-required restricted substance requirements. We use an independent laboratory to complete testing for certain restricted substances that may be contained in our hardware products. We use test results to validate supplier material declarations and monitor conformance to our restricted substances specification throughout the product lifecycle. Microsoft has implemented additional measures to ensure suppliers, and materials used in Microsoft products, adhere to Microsoft standards. Supplier conformance is verified through the restricted substance control (RSC) audit program which audits supplier control system capabilities.

Global Restriction of Hazardous Substances (RoHS) compliance

All Microsoft hardware [1] products are designed to comply with the applicable restricted substance requirements of the European Union’s Restriction of the use of certain Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive (2011/65/EC) as amended, including Directive (2015/863/EU) which added four phthalates to the RoHS Directive’s Annex II substance restriction list. The RoHS Directive requires self-declaration to RoHS restrictions through the EU Declaration of Conformity (EU DoC) process and CE marking. In addition, the United Kingdom RoHS (2012) regulation requires self-declaration through the UK Declaration of Conformity (UK DoC) process and UKCA marking.
 

By designing Microsoft hardware products to meet EU RoHS requirements, Microsoft also achieves compliance with other countries’ laws that duplicate the RoHS Directive’s substance restrictions for a similar scope of covered products, including, but not limited to, China Management Methods for Controlling Pollution by Electronic Information Products, Korea Enforcement Ordinance on the Recycling of Electrical and Electronic Equipment and Vehicles Act 2007, Taiwan RoHS Regulation, Japan’s Law for Promotion of Effective Utilization of Resources and California’s Electronic Waste Recycling Act.

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[1]Note: EU RoHS, by definition, does not apply to Microsoft software products, packaging, or optical media (CD-ROMs and DVDs).

California Proposition 65

California’s Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a ballot initiative in November 1986. The Proposition was intended by its authors to protect California citizens and the State's drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and to inform citizens about exposures to such chemicals. Based on our product design and our supplier material disclosures, we have determined that Microsoft products do not contain chemicals in amounts that would trigger a notification or warning under Proposition 65.

REACH compliance

The European Union’s Regulation on the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) (2006/1907/EC) entered into force on June 1, 2007. Pursuant to Article 33, Microsoft communicates information regarding Substances of Very High Concern (SVHC) that are contained in articles in a concentration above 0.1% by weight to its customers and to consumers, upon request. To meet these compliance obligations, Microsoft actively monitors the European Chemical Agency’s (ECHA) SVHC candidate list and adds SVHCs that have been added to the ECHA authorization list.

EU REACH Article 33 Disclosure

Refer to the Microsoft EU REACH declaration for Microsoft EU REACH compliance documentation below, which includes the Substances of Concern in Products (SCIP) database obligations which went into effect on January 5, 2021.

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UK REACH Article 33 Disclosure

The United Kingdom’s REACH Regulation entered into force on January 1, 2021, and regulates chemicals placed on the market of Great Britain. Microsoft provides the following UK REACH Article 33 Disclosure which communicates information on UK SVHCs that are contained in articles above a concentration of 0.1% by weight.

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Ozone-depleting substances

The Montreal Protocol on Substances that Deplete the Ozone Layer (“Montreal Protocol”) restricts the use of Ozone-depleting substances (ODSs) in manufacturing and Sections 4681 and 4682 of the U.S. Internal Revenue Code (IRC) impose an excise tax on the sale or use of ODSs. Any importation of ODSs or products containing ODSs are subject to the IRS excise tax. To ensure compliance, Microsoft has prohibited the use of ODSs in the manufacture of Microsoft devices. Microsoft uses a three-pronged approach to enforce this prohibition: (1) Microsoft’s restricted substance specification, H00594, that all suppliers must meet, (2) an annual supplier disclosure covering ODSs, and (3) supplier audits to validate supplier ODS claims.

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Phasing out substances of concern

We proactively evaluate substances based on a scientific approach and the precautionary principle and phase out substances from the entire product range when environmentally preferable alternative materials are feasible and available. These materials are added to our restricted substances specification based on Microsoft policy as opposed to legal requirements.

 

When a new substance is restricted by law or Microsoft policy, we quickly identify the components containing the substance, along with the related suppliers, by searching our database of full material declarations.

 

By working together with the supply chain, as well as other key stakeholders, we ensure that best practices are adopted and promoted, producing industry-wide impact. This approach to substance management is also actively communicated to policy makers, regulators, NGOs, and other interested parties.

 

We voluntarily submit our products for independent third-party testing during the development and manufacturing processes. We use third-party testing to verify our supplier material declarations and to confirm that restricted substances that have a high risk of being present are not contained in supplied products and packaging. As an additional precaution, third-party auditors monitor suppliers for proper implementation of controls to maintain conformance to the Microsoft Restricted Substances for Hardware Products Specification, H00594. The restricted substances specification is updated, at a minimum, annually to reflect regulatory changes and new Microsoft specific substance restrictions.

 

Lead, mercury, cadmium
We phased these substances out of our products to comply with the European Union’s RoHS Directive, and we require stricter limits in certain applications for precautionary purposes.

 

Halogenated flame retardants
We meet legal requirements and have voluntarily phased out many halogenated flame retardants in certain applications.

 

Nickel
All our devices comply with strict global safety and quality standards. Some metal alloys are used on product surfaces, such as stainless steel. While stainless steel may contain nickel, product surfaces are tested to comply with legal standards and to ensure that they do not cause nickel sensitivity in the general population. We offer a wide range of devices without stainless steel on their surfaces as well.

 

Phthalates
The use of certain phthalates in our products has been restricted since 2005. We now restrict the use of a broad set of phthalates in all consumer devices, including those regulated by the European Union Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) Regulation, EU RoHS, and California Proposition 65.

 

PFAS
Per- and Polyfluoroalkyl Substances (PFAS) are a large family of synthetic chemicals that include over 10,000 individual chemicals. Our products are designed to meet all existing PFAS regulatory requirements, including, but not limited to:

•    EU REACH (2006/1907/EC) restriction on C9-C14 PFCAs, their salts and related substances
•    EU Persistent Organic Pollutants (POPs) Regulation (2019/1021) restriction on PFOA and PFOS
•    Switzerland Ordinance on the Reduction of Risks relating to the Use of Certain Particularly Dangerous Substances restriction on C9-C14 PFCAs and PFHxS

We are aware of the proposed and enacted regulations targeting the restriction of all PFAS in various and are committed to complying with all PFAS regulatory requirements within the prescribed timeline.

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