HPD documentation checklist for products with electronics
Electronics inside a product raise the bar for HPDs. Ingredient screening must reach into PCBs, solders, resins, and tiny connectors, not just the outer housing. Teams that define the document set up front avoid supplier ping‑pong and keep LEED or WELL reviews moving. Here is the tight list of certificates and proofs that prevent last minute scrambles.
Why electronics trigger extra paperwork
HPDs for electronics are scrutinized because small parts can carry restricted substances in concentrated pockets. Think of a control board as a city block where each building has different rules. Reviewers want proof that every component was checked, not just the skyline.
Core compliance statements reviewers expect
- Restriction of Hazardous Substances compliance letter that states threshold control for the ten RoHS substances. The practical bar remains 0.1 percent by weight for most, and 0.01 percent for cadmium, documented per the directive and applicable exemptions (European Commission RoHS, 2024) (European Commission RoHS, 2024).
- REACH status letter that covers Candidate List communication duties for any Substance of Very High Concern at or above 0.1 percent by weight of the article, part by part, plus intended uses and safe use info when required (ECHA, 2024) (ECHA, 2024).
- Halogen free or low halogen declaration if you claim it. Use an accepted electronics convention for chlorine and bromine limits and note the test method so the claim is defensible.
- California Proposition 65 assessment and, where relevant, the chosen warning approach. Even when warnings are not needed, document the reasoning.
- Battery or power supply attestations when applicable. Align with relevant safety marks and the new EU Battery Regulation context if you sell into that market.
Substance declarations that survive audits
BOM level disclosure should map every homogeneous material to a substance list with CAS numbers. For HPDs, most teams target the 100 ppm inventory threshold when feasible, since the Open Standard uses that level for full credit and consistent screening against hazard lists (HPDC Open Standard v2.3, 2024) (HPDC Open Standard v2.3, 2024). Use a structured format that supply chains already understand, such as IEC 62474 or IPC 1754, then attach supplier signoffs.
Emissions and toxicity evidence that backs the story
If the product claims low emissions, include a current chamber test for VOCs using the California Department of Public Health Standard Method. For claims like no intentionally added PFAS or certain phthalates, add targeted analytical reports or a lab letter that states the method and reporting limit. Third party certifications such as GREENGUARD or SCS Indoor Advantage can do double duty as proof of method and result.
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When electronics sit inside a larger assembly
The HPD covers the finished product. That means the enclosure, adhesives, cable jackets, thermal pads, and the board all need to roll up into one coherent declaration. Provide a parts map that links each supplier certificate to a unique line in the BOM so a reviewer can trace any claim to its document in one hop.
The alignment playbook, kept short
- Lock the part numbering scheme. Every subcomponent needs a stable ID before supplier outreach.
- Request certificates in the same unit basis as the BOM, usually homogeneous material or article level. Avoid mixture only letters when a part is clearly an article.
- Capture testing details. Note method, lab, date, detection limits, and sample IDs. That is what turns a claim into evidence.
- Tag SCIP numbers or material class codes where they exist. Even when not required for the HPD, they speed later checks.
Timing and renewal watchouts
RoHS exemptions and the REACH Candidate List change more frequently than most product refresh cycles. Set a calendar to recheck high risk parts before big submittals, not after a reviewer asks. If a claim depends on a lab report, give yourself buffer time because retesting can take weeks. We often see teams loose steam waiting for a single connector letter to arrive.
What to ask suppliers on day one
- A signed RoHS and REACH statement that references the current year and includes part numbers covered.
- A material declaration with CAS numbers and thresholds that match the HPD plan.
- Any current emissions or targeted tox reports, with methods and detection limits shown.
- A clear statement of halogen content if you plan to market halogen free designs.
- Contact info for regulatory or quality staff who can quickly confirm edge cases.
Make the review boring, on purpose
The goal is not flash, it is traceability. If every claim in the HPD points to a stable certificate, a lab report, or a supplier declaration that matches the BOM, LEED v5 and WELL reviewers move faster. Your team spends less time defending, and more time shipping product to spec. The best HPD files feel like a packed suitcase where every cable is already coiled, you just zip and go.
(HPDC Open Standard v2.3, 2024) (HPDC Open Standard v2.3, 2024)
(European Commission RoHS, 2024) (European Commission RoHS, 2024)
(ECHA, 2024) (ECHA, 2024)
Frequently Asked Questions
Are RoHS and REACH documents always required for HPDs with electronic components
Not always by law for the HPD itself, yet they are commonly requested during LEED or WELL reviews to substantiate hazard screening and ingredient claims. RoHS thresholds are 0.1% for most restricted substances and 0.01% for cadmium, while REACH Article 33 requires communication at 0.1% w/w of an article. These numeric triggers are why reviewers ask for them. (European Commission RoHS, 2024) (ECHA, 2024).
What testing is most useful to back low emissions claims for electronics-containing products
A current chamber test to the California Department of Public Health Standard Method is widely accepted for low emitting materials claims. Certifications like GREENGUARD or SCS Indoor Advantage can package the test and verification in one document.
How deep should substance disclosure go in an HPD for electronics
Aim for CAS-level substance disclosure to 100 ppm when feasible, structured to IEC 62474 or IPC 1754. This aligns with the HPD Open Standard’s full disclosure level and makes hazard screening repeatable across updates. (HPDC Open Standard v2.3, 2024).
About the Author
Walker Ryan is a climate-tech entrepreneur focused on driving industrial decarbonization through better data. As the founder and CEO of Parq, he helps manufacturers generate high-quality, third-party–verified carbon disclosures at scale—accelerating a traditionally slow and expensive process. Before starting Parq, Walker led over $200 million in sustainability-focused investments as VP of Strategy & Growth at ReStream Solutions, following earlier experience in investment banking at Deutsche Bank. He brings a rare mix of capital markets expertise and hands-on sustainability knowledge to tackling the infrastructure of industrial emissions.
