HP’s Compliance with Restriction of Hazardous

Substances (RoHS) Legislation in the EU and

other jurisdictions
(Rev 14d April 2022)
HP is committed to compliance with all applicable laws and
regulations, including material restriction requirements under the
European Union Recast RoHS Directive 2011/65/EU, otherwise known
as EU RoHS 2, as amended by Directive 2015/863/EU and RoHS
HP Inc
1501 Page Mill Road legislation in other jurisdictions such as China’s Management Methods
Palo Alto, CA 94304-1112 for Restricted Use of Hazardous Substances in Electrical and Electronic
[Link] Products, otherwise known as China RoHS, and the materials
restriction requirements of India’s E-Waste Management Rules, 2016.
HP believes that legislation, like EU RoHS 2, plays an important role in
promoting industry-wide transition to restrict substances of concern. In
general, the restriction of any substance should take into account the
following key items:

• Global harmonization of the legislation content and implementation

requirements
• Substance risk assessment, including a clear understanding of the
environmental impacts of alternative substances
• Clear identification of what substances (vs. broad classes or
categories) are to be restricted
• Clear identification of when alternative technologies are proven and
readily available
• Appropriate lead time to allow the industry to transition
• Substances that are not used or found in final products should not be
included in the restrictions
• Material application exemptions should be allowed for the use of
restricted substances in applications where current substitution is not
technically feasible
• Inclusion of maximum concentration values setting de minimis levels
below which the relevant substances may be present

HP believes other substances should be considered for inclusion in

future RoHS legislation. This includes the restriction of polyvinyl
chloride (PVC) and brominated flame retardants (BFRs) from electrical
and electronic products (EEE). HP believes PVC and BFRs should be the
focus for the restriction of chlorine (Cl) and bromine (Br) from electrical
and electronic products, where technically feasible. HP’s reasons for
focusing on PVC and BFRs are:
• PVC and BFRs cover 99% of the uses for Cl and Br in electronics;
• Given the high percentage usage, these substances have the highest
impact;
• Restriction of these substances where technically feasible would
substantially accomplish the goal to eliminate Cl and Br from
electronic products

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 In order to make these material transitions in all the many types of products in
the industry, HP believes restriction under RoHS legislation is possible.
However, some critical issues would need to be overcome or addressed by
specific exemptions, including technical issues for certain applications,
availability of environmentally preferable alternatives, and ability to maintain
high recycled content as substances are restricted.

Our continued voluntary goal is to apply the EU RoHS 2 substance and

exemption requirements outside the EEA (and other countries that are tracking
EU compliance dates) on a worldwide basis within 6 months of each of the EU’s
various legal compliance dates for virtually all HP branded new products in the
scope of EU RoHS 2, except where it is widely recognized that there is no
technically feasible alternative (as indicated by an exemption under the EU
RoHS Directive).

HP began proactively eliminating substances of concern in the early 1990s.

The HP Materials and Chemical Management Policy guides how we specify
materials and chemicals for use in products, packaging, and manufacturing
processes. For key milestones see our Green Chemistry Timeline.
In early 2003, a company-wide RoHS team was formed to manage all aspects
of HP’s global response to RoHS legislation around the world. HP’s initiative to
address RoHS legislation is part of the company’s Design for Sustainability
program, which includes advancing materials innovation to improve
environmental and human health impacts. For more information, see the
materials innovation section of HP’s Sustainable Impact Report.

HP continues to plan for further “RoHS like” legislations in other jurisdictions

and will meet any additional requirements that arise. HP complies with the
requirements of all the RoHS legislations currently in effect (including those
specifically listed under Compliance Status below). HP’s Compliance
Verification is based on our risk analysis of restricted substances entering the
supply chain and includes technical documentation outlined in the European
Union’s EN 50581:2012 standard and the International EN IEC 63000:2018
standard.

More detailed information can be found at: Sustainable Impact at HP

Sustainability Impact Report

Sustainable Design
Compliance Verification
General Specifications for the Environment
Eco Declarations

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 HP’s Compliance Status to EXISTING RoHS Legislation:

Europe, Middle East and Africa

European Union (EU) and European Economic Area (EEA)

• HP products [1] comply with EU Directive 2011/65/EU of 8 June 2011 as
amended by EU Directive 2015/863 of 31 March 2015 and including
amendments to the exemptions in Annex III.

Switzerland
• HP products [1] comply with the Swiss Ordinance on the Reduction of Risks
relating to the Use of Certain Particularly Dangerous Substances, Preparations
and Articles, otherwise known as the Swiss Chemical Risk Reduction
Ordinance, ORRChem, as of May 18, 2005 (as amended)

Ukraine
• HP products [1] comply with the substance restrictions in Ukraine’s “Technical
Regulation on Restriction of the use of certain hazardous substances in
electrical and electronic equipment, approved by Decree of the Cabinet of
Ministers of Ukraine dated 10 March, 2017 No. 139”, otherwise known as
Ukraine RoHS which came into effect on 22 September 2017 and repealed
Technical Regulation on the restriction of the use of certain hazardous
substances in electrical and electronic equipment, approved by Decree of the
Cabinet of Ministers of Ukraine dated December 3, 2008 No. 1057.

Serbia
• HP products [1] comply with Serbia's WEEE and RoHS "Regulations on the List of
Electrical and Electronic Products, Measures Banning and Restricting the
Recovery of Electrical and Electronic Equipment Containing Hazardous
Materials, and the Methods and Procedures for Managing Waste from
Electrical and Electronic Products" that entered into force on January 4, 2011.
RoHS restrictions apply to equipment placed on the market on or after July 1,
2011.

Turkey
• HP products [1] comply with Turkey’s “Regulation on Waste Electronic and
Electrical Equipment” (WEEE) which came into effect on May 22, 2012 and
incorporates the rules for the Restriction of Certain Hazardous Substances in
Electrical and Electronic Equipment”, otherwise known as Turkey RoHS.

Bosnia-Herzegovina
• HP products [1] comply with Bosnia-Herzegovina’s “Regulation of Restrictions
of Use of Certain Dangerous Substances in Electrical and Electronic Equipment
(RoHS Regulation 50/15) was published in Official Gazette of Republic of
Srpska 50/15”, otherwise known as Bosnia-Herzegovina RoHS, which came
into effect on June 1, 2016.

United Arab Emirates (UAE)

• HP products [1] comply with UAE’s “Cabinet Decision No. 10/2017 to control
hazardous materials in electrical and electronic devices (RoHS) OG No. 614 of
27.04.2017 (officially published and came to power on 16.05.2017)”,
otherwise known as UAE RoHS, which came into effect on January 1, 2018.

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 Eurasian Economic Union (EAEU)
• HP products [1] comply with EAEU’s “Technical Regulation EEU 037/2016 on
restriction of use of hazardous materials in electrical and radio electronic
devices (RoHS), published October 18, 2016”, otherwise known as EAEU RoHS,
which came into effect on March 1, 2020.

United Kingdom (UK)

• HP products [1] comply with UK’s “The Restriction of the Use of Certain
Hazardous Substances in Electrical and Electronic Equipment Regulations
2012/ No. 3032”, otherwise known as UK RoHS, which came into effect on
January 2, 2013.

Asia
China
• HP products [1] comply with China’s, “Management Methods for Restricted Use
of Hazardous Substances in Electrical and Electronic Products”, otherwise
known as China RoHS which came into effect on July 1, 2016. And comply with
“Catalog of Electrical and Electronic Products that have met the standard in
Limited Use of Hazardous Substances (Batch one) which comes into effect on
Nov 1, 2019.

India
• HP products [1] comply with the material restrictions of India’s legislation “E-
waste Management Rules, 2016”, otherwise known as India RoHS which came
into effect on October 1, 2016.

Korea
• HP products [1] comply with Korea’s legislation “The Act on Resource
Circulation of Electrical and Electronic Equipment and Vehicles”, otherwise
known as Korea’s RoHS which came into effect on January 1, 2008. You can
find HP’s Korean RoHS declarations at: [Link]
information/environment/[Link].

Vietnam
• HP products [1] comply with Vietnam’s legislation “Circular 30/2011/TT-BCT:
Temporarily regulating the permitted limits for a number of hazardous
substances in electric and electronic products”, otherwise known as Vietnam
RoHS which came into effect on December 1, 2012. You can find HP’s Vietnam
RoHS declarations at: [Link]
information/environment/[Link]

Japan
• HP products [1] comply with the labeling requirements set out in Japan’s “The
Marking of Presence of the Specific Chemical Substances for Electrical and
Electronic Equipment” (JIS-C-0950), otherwise known as J-MOSS which came
into effect on July 1, 2006. You can find HP’s J-MOSS declarations at
[Link]
[Link]

Singapore
• HP products [1] comply with Singapore’s “Environment Protection and
Management Act (Chapter 94A) Environmental Protection and Management

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 Act (Amendment of Second Schedule) Order 2016”, otherwise known as
Singapore RoHS which came into effect on June 1, 2017.

Taiwan BSMI
• HP products [1] comply with Taiwan’s “CNS 15663 Guidance to reduction of the
restricted chemical substances in electrical and electronic equipment released
by Bureau of Standards, Metrology and Inspection (BSMI), MOEA through
notification dated 29 December 2015 added the requirement for RoHS
labelling to BSMI certification requirement.” Otherwise known as Taiwan BSMI
RoHS which came into effect as of July 1, 2017.

Americas
California
• HP products [1] comply with California’s, “Electronic Waste Recycling Act of
2003 (Senate Bill 20) substance restrictions”, otherwise known as California
RoHS which came into effect on January 1, 2007.

New Jersey
• HP products [1] comply with New Jersey’s “Electronic Waste Recycling Act”
(Senate Bill 2144), otherwise known as New Jersey RoHS which came into
effect on 1 January 2011.

Worldwide

• HP continues to achieve its internal voluntary goal to meet the substance

restrictions of the EU RoHS legislation on a worldwide basis, except where it is
widely recognized that there is no technically feasible alternative (as indicated
by an exemption under the EU RoHS Directive), for virtually all HP branded
products in scope of EU Directive 2011/65/EU as amended.

Notes:
[1] HP products that are both in scope and put on the market in the given jurisdiction.

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