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 a scientific approach and the precautionary principle. Where we have reasonable grounds for 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 beyond legal requirements.

Microsoft has created several environmental compliance specifications to inform suppliers of restricted substance requirements and to establish documentation controls for achieving such requirements, as follows:

  • Microsoft Restricted Substances for Hardware Products Specification (H00594) This document includes the restrictions for substances and chemicals that may not be used in our hardware products, packaging, and in the manufacturing of our products.
  • Restricted Substances Control System for Hardware Products (H00642) This document contains the documentation requirements that suppliers must provide to demonstrate their adherence 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. Having full material declarations allows us to respond swiftly if new concerns arise about any substance, or if the regulatory landscape expands beyond the current Microsoft substance restrictions in H00594.

These specifications work together to ensure all parts, components, products, and packaging supplied to Microsoft meet global and Microsoft-specific restricted substance requirements. We use an independent laboratory to complete testing for certain restricted substances in all our hardware products. We use test results to validate supplier material declarations and monitor compliance throughout the product life cycle.

Global Restriction of Hazardous Substances (RoHS) compliance

All Microsoft’s 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 by the EU RoHS Recast Directive (2015/863/EU). The EU RoHS Recast requires self-declaration to RoHS restrictions through the Declaration of Conformity (DoC) process and CE 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. 

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

California Proposition 65

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. None of Microsoft’s products contain chemicals in amounts that would trigger a notification or warning under California Proposition 65.

EU 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. Microsoft actively monitors the European Chemical Agency’s SVHC candidate list and restricts SVHCs that have been added to the ECHA authorization list.

Download our REACH Article 33 Disclosure on Environmental Compliance

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 US Internal Revenue Code (IRC) impose an excise tax on the sale or use of ODSs by the manufacturer, producer or importer of the ODS and the sale or use in the United States by the importer of any “imported taxable products.” Any importation of ODSs or products containing ODSs are subject to the IRS excise tax. To ensure compliance, Microsoft has established a strong company policy on prohibiting the use of ODSs in the manufacture of Microsoft devices. Microsoft uses a three-pronged approach to achieve this policy: a restricted substance specification that all suppliers must meet, an annual supplier disclosure covering ODSs, and supplier audits that validate supplier ODS claims.


We proactively evaluate substances based on a scientific approach and the precautionary principle and phase out substances from the entire product range when feasible and environmentally preferable alternative materials are available. When a new substance is restricted by law or Microsoft policy, we are able to quickly identify the components containing the substance along with the related suppliers by simply 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 the supplied products and packaging. As an additional precaution, third-party auditors monitor suppliers for proper implementation of controls to maintain compliance with in the “Microsoft Restricted Substances for Hardware Products” specification, H00594. The restricted substances specification is updated at a minimum, annually to reflect regulatory changes and additional Microsoft specific substance restrictions.

Lead, mercury, cadmium

We phased these substances out of our products to conform with the European Union’s RoHS Directive, but require stricter limits for cadmium.

Halogenated flame retardants

We have restricted and limited many halogenated flame retardants as specified in H00594, “Microsoft Restricted Substances for Hardware Products” specification. We meet legal requirements and have voluntarily phased out many halogenated flame retardants in certain applications.


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, 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.


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 referenced in European Union Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH), EU RoHS, and California Proposition 65.

Find out more in our Environmental Compliance Letter.

Questions? Ask the environmental compliance team (askect@microsoft.com)