Safety, Compliance & Sustainability
MICROSOFT ANALYTICAL LABORATORY TESTING
REQUIREMENTS
Author:
Environmental Compliance & Sustainability
Document: H02446
Revision:
U
Date:
September 11, 2020
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Classified as Microsoft General
Title: MICROSOFT ANALYTICAL LABORATORY TESTING REQUIREMENTS
Document No. H02446
Revision: U
Date: 9/11/2020
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Safety, Compliance & Sustainability
Microsoft and its suppliers may have patents, patent applications, trademarks, copyrights, trade
secrets and/or other intellectual property rights covering subject matter in this document.
Microsoft’s furnishing of this document to recipient does not grant or imply any license to any
patents, trademarks, copyrights, trade secrets or other intellectual property rights, and
recipient’s permitted use of any such intellectual property rights, if any, is solely governed by the
Agreements.
© 2020 Microsoft Corporation. All rights reserved.
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Title: MICROSOFT ANALYTICAL LABORATORY TESTING REQUIREMENTS
Document No. H02446
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1
RECORD OF REVISIONS
Release
Letter
U
Date
Summary of Changes
Author/Approver
9/11/2020
Add test report language requirement in section 7.
Environmental Compliance Team
Update PAHs testing method in Table 5.
Add test requirements when manufacturer production site
change in section 5.
Update testing items and report language in Appendix B
testing application form.
T
6/14/2019
Update test methods. Remove the contact in testing
application form.
Environmental Compliance Team
S
10/9/2017
Structure of the document changed. Requirements in
product and substance level clarified.
Environmental Compliance Team
R
09/15/2015
No Rev Q. Added a sentence that this document lists
supplier’s in-house labs only, section 1.
Environmental Compliance Team
P
08/28/2014
No O rev. Removed Chicony as an approved lab due to
invalid ISO 17025 Certificate.
Environmental Compliance Team
N
01/11/2013
Added DiBP (Phthalate), note to Table 1
Environmental Compliance Team
M
12/11/2011
-Corrected duplicate information in Table 2 Corrected
Section numbering in document. Updated Foxlink Contact
Information in Table 3. Removed Section 1.1 Scope for
brevity and clarity.
Environmental Compliance Team
L
07/15/2011
Added Packaging and batteries testing requirement.
Removed list of 3rd party labs (former Appendix B) and
replaced it with Test Report Requirements. Revised
Appendix D to include testing for packaging and batteries.
Removed NMB, KYE, Kinpo, Celestica, Tyco and Ji Haw labs
from Appendix A.
Environmental Compliance Team
K
5/29/09
Removed PAHs. Added IEC 62321. Removed restriction on
Phthalate testing for third party labs
Environmental Compliance Team
J
7/31/08
Added Supplier in-house lab’s addresses. NMB Thailand
and Foxlink Gung Le Fu Yao labs removed (no longer test
for Microsoft). Included PAH test Requirements. Expanded
Intertek and SGS location for phthalate testing.
Environmental Compliance Team
H
11/21/07
Update lab list.
Environmental Compliance Team
All Professional Labs with ISO 17025 accreditation are now
qualified to do RoHS testing.
Removed references to H03562.
G
03/16/07
Changed document title, added a section for analytical
testing process, and testing methodologies, including
Phthalate and Toy.
Environmental Compliance Team
F
10/10/2006
Added approved labs.
Environmental Compliance Team
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Title: MICROSOFT ANALYTICAL LABORATORY TESTING REQUIREMENTS
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E
08/18/05
Added approved labs.
Environmental Compliance Team
D
07/08/05
Approved labs and Lab approval process added.
Environmental Compliance Team
C
05/09/05
Test methods added, removed Excel spreadsheet and
added approved lab list tables in Word document in the
Appendices.
Environmental Compliance Team
B
01/12/05
Intertek labs added
Environmental Compliance Team
A
12/07/04
Initial Release
Environmental Compliance Team
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Title: MICROSOFT ANALYTICAL LABORATORY TESTING REQUIREMENTS
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Table of Contents
1
RECORD OF REVISIONS .................................................................................................. 3
2
FOREWORD ..................................................................................................................... 7
3
PURPOSE ......................................................................................................................... 7
4
COMPONENT AND MATERIAL TESTING........................................................................ 7
5
6
7
4.1
Third Party Professional Lab ......................................................................................... 7
4.2
Supplier In-House Lab .................................................................................................. 8
TESTING OF FINAL PRODUCTS.................................................................................... 8
REQUIREMENTS FOR COMPLIANCE TESTING ........................................................... 8
TEST REPORT LANGUAGE ..........................................................................................11
APPENDIX A:
TEST REPORT REQUIREMENTS ...................................................................12
APPENDIX B:
MICROSOFT RESTRICTED SUBSTANCE PRODUCT TESTING FORM...........14
APPENDIX C:
SAMPLE SHIPPING INSTRUCTIONS ...........................................................14
APPENDIX D:
NICKEL PLATING APPLICATION EXAMPLES ..............................................16
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DOCUMENT CONTROL
SPECIFICATION
Document Owner:
Environmental Compliance and
Sustainability Team
Approval: Director of Environmental Compliance
Signature: Electronic signatures on SCS
SharePoint list
Approval Date: September 11, 2020
Update Requirements: The General Manager or designee shall maintain this procedure. This
procedure must be reviewed and approved annually. This document and its revisions shall
remain current for no more than one year from the approval date. The General Manager or
designee must retain a log of document history with this procedure.
References
Microsoft External
1. H00642: Restricted Substance Control System
2. H00594: Restricted Substances for Hardware Products
Attachments
1. Appendix A: Test Report Requirements
2. Appendix B: Microsoft Restricted Substance Final Product Testing Form
3. Appendix C: Sample Shipping Instructions
4. Appendix D: Nickel Plating Application Examples
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2
FOREWORD
While Microsoft will conduct analytical testing on certain supplied products and packaging,
Microsoft does not guarantee or represent any certification(s) of compliance for those supplied
products and packaging. The supplier is solely responsible to deliver products and/or packaging
which conform to H00594 Substance Restriction requirements and all applicable legal and
contractual requirements. Microsoft does not, by its provision of this testing process, assume
any responsibility for the compliance of any supplier-manufactured products and/or packaging.
Each supplier will be solely responsible for the compliance status of any supplied product and/or
packaging as well as any related corrective actions and/or resulting damages in accordance with
the contract between Microsoft and the supplier.
3
PURPOSE
Microsoft specification H00594 Restricted Substances for Hardware Products defines the
substances that are restricted in Microsoft products and packaging. Suppliers are responsible for
providing substantiated evidence in the form of Full Material Declarations and analytical test
reports, when requested, that attest to the absence of Microsoft restricted substances in
products and packaging that they supply to Microsoft. These requirements are outlined in
H00642 Microsoft Restricted Substances Control System for Hardware Products. In addition,
Microsoft will conduct product testing to ensure these requirements are met per Section 4.
4
4.1
COMPONENT AND MATERIAL TESTING
Third Party Professional Lab
Microsoft accepts component and material analytical test reports issued by a professional thirdparty lab that meets the following minimum requirements:

Results must be appropriately formatted as described in Appendix A of this
specification and be sent to Microsoft as directed by the Environmental Compliance
Engineer.

Lab report file name meets the requirement of H00642

The lab must have accreditation (based on ISO 17025) from relevant agencies (e.g.,
China CNAS, Taiwan CNLA, Korea KOLAS, Hong Kong HOKLAS, Singapore SINGLAS)

For China RoHS certification, the third-party lab must be approved by the Chinese
Governmental Bureau, which may include additional requirements.
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4.2
Supplier In-House Lab
While suppliers may test materials in-house as part of their internal Quality Assurance/Quality
Control processes, these test results are not accepted by Microsoft as compliance
documentation. Component and material analytical test reports provided as compliance
documentation must be issued by a professional third-party lab meeting the requirements of
Section 4.1.
Examples of Supplier in-house testing for Quality Assurance/Quality Control processes may
include inspections on incoming materials, outgoing products, and their manufacturing process
using XRF (X-Ray Fluorescence) equipment or a chemical lab at the factory. XRF equipment is
used to scan the chemical elements contained in the scanned item and is a useful screening
process for heavy metals specifically but cannot identify isomers or chemical compounds.
Chemical test methods provide more accurate methods to identify these substances or
compounds and only testing conducted by an accredited laboratory are acceptable as
compliance documentation per Section 4.1.
5
TESTING OF FINAL PRODUCTS
Microsoft will require Tier 1 suppliers to provide samples of final products to the Microsoft
specified external lab for analysis. This testing process applies to all Microsoft hardware,
software, games, figurines, and their packaging. Microsoft testing requirements are defined in
Appendix B: Microsoft Restricted Substance Final Product Testing Form. Shipping instructions
are defined in Appendix C. Microsoft’s compliance process specifies that the product testing
must be completed before the product is released to production. After production release,
periodic testing throughout the product life must be conducted as defined by the Microsoft
responsible environmental compliance engineer.
When the existing production site is moved to a new location, supplier will be required to
provide test reports for the final product from new production site. Please refer to section 6 for
test requirements.
6
REQUIREMENTS FOR COMPLIANCE TESTING
Microsoft’s analytical testing requirements and the applicable testing requirements for each
substance are provided in Tables 1-7. The testing requirements set forth below are a subset of
the restrictions defined in the H00594 Restricted Substances for Hardware Products
Specification.
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Requirements for all Hardware Products (Groups 1-3)
Substances to be tested
Lead (Pb)
Cadmium (Cd)
Mercury (Hg)
Hexavalent Chromium (Cr VI)
polybrominated biphenyls ethers (PBBs)
polybrominated diphenyl ethers (PBDEs)
Phthalates to be tested for ALL soft
plastics
All Phthalates in H00594 (Appendix C of
H00594)
Test method
IEC62321 series
depending on
substance and
application
GB/T 26125-2011
IEC62321-8:2017
Requirements for Group 2 Products
Substances to be tested
(external surface)
Aluminum
Antimony
Arsenic
Barium
Boron
Cadmium
Chromium (III)
Chromium (VI)
Cobalt
Copper
Lead
Manganese
Mercury
Nickel
Selenium
Strontium
Tin
Organic tin
Zinc
Test method
EN71-3 the latest version
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Requirements for Packaging (including Software and Games)
Substances to be tested
Cadmium, Lead, Mercury,
Hexavalent Chromium
Test method
Alkaline digestion or acid
digestion
Requirements for Batteries
Substances to be tested
Cadmium
Lead
Mercury
Symbol labeling review
Test method
Total digestion and
GB/T 26125-2011, both
required
Article 21 of 2006/66/EC & US
Public Law 104-142
Requirements for Skin Sensitizer testing
Substances to be tested
Nickel (including Stainless
Steel and Nickel Anodized
materials)
Non-Nickel plating in HSC
areas
(Restricted in HSC areas)
Skin Sensitizer Category 1
Substances (other than Nickel)
PAHs1 (All accessible plastic or
rubber parts that come into
direct, prolonged or repetitive
skin or oral cavity):
Acenaphthene
Acenaphthylene
Anthracene
Benzo[a]anthracene
Benzo[a]phenanthrene or
chrysene
Benzo[a]pyrene
Benzo[b]fluoranthene
Benzo[e]pyrene
Test method
EN1811
EN12472 + EN1811
Modified EN 1811
AfPS GS 2019:01 PAK
1
PAH Test reports must be provided for paints to be used in accessible plastic or rubber parts that come
into direct, prolonged or repetitive skin or oral cavity must meet the threshold of H00594 Table1.
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Benzo[g,h,i]perylene
Benzo[j,k]fluorene or
fluoranthene
Benzo[j]fluoranthene
Benzo[k]fluoranthene
Dibenzo[a,h]anthracene
Fluorene
Indeno[1,2,3-cd]pyrene
Naphthalene
Phenanthrene
Pyrene
Note: Microsoft’s Product Safety Engineer shall determine the High Skin Contact
(“HSC”) areas on the product for purposes of Table 6. The HSC areas are those
which are subject to repeated and prolonged skin contact under normal/expected
use conditions. Microsoft may conduct additional testing for HSC materials based
on potential risk. See Appendix D for acceptable Nickel applications.
Requirements for Surface computer devices and power supply units
Substances to be tested
Bromine element in printed
circuit boards and plastic parts
Chlorine element in printed
circuit boards and plastic parts
Beryllium in metal connectors,
springs, and shields
Test method
EN14582:2016
EPA 3052:1996 + EPA
6010D:2014
Requirements for Surface Motherboards
Substances to be tested
HBCDD
7
Test method
EPA 3540C
TEST REPORT LANGUAGE REQUIREMENTS
All test reports must be in English. Surface devices and the accessories will require an English
report with EU standard and a Chinese report with Chinese standard.
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APPENDIX A: Test Report Requirements
Please ensure the following requirements are included in analytical lab methods and reporting
requirements for Microsoft products:
1)
Calibration Methods
Linear calibration curve procedures for ICP and AA analyzers must include standard solution
concentrations, which span the range of equivalent concentrations for Lead (Pb) and Cadmium
(Cd) reported in samples analyzed, and include equivalent concentrations for Pb and Cd at the
specification limit in samples. Concentrations equal to the Pb and Cd at the specification limit in
samples can be calculated as follows for the standard digestion and analysis methods:
Conc. of analyzer calibration standard solution = Spec limit (ppm) X Weight of sample (in
grams)/100
For a 0.5 gram sample, the calculations are shown below assuming standard methods with no
dilution (DF=1):
Conc. of Pb calibration standard (ppm) = Pb Spec limit (100 ppm) X 0.5 gram/100 = 0.5
ppm
Conc. of Cd calibration standard (ppm) = Cd Spec limit (75 ppm) X 0.5 gram/100 = 0.375
ppm
2)
Analysis methods
Each batch of samples processed for analysis must include spike and blank samples which are
digested and analyzed in the same batch as the samples. The spike sample concentration should
equal the Pb and Cd specification limit values (100 ppm for Pb; 75 ppm for Cd).
3)
Reporting
Any result which is below the Practical Quantification Limit (PQL) calculated for the sample must
be reported as non-detect (ND) at the PQL. For example, if the analyzer result is calculated to be
equivalent to 2 ppm for a sample with a PQL of 5 ppm, the result is reported as "ND". Reporting
of results must include the following:

Sample identification, sample analysis result, PQL for sample.
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


Blank identification, blank analysis result, PQL for blank.
Spike identification, spike concentration, spike analysis result, % recovery.
Any abnormalities occurring during sample preparation, digestion or analysis.
Example Information Required in Analytical Test Reports
Information Required
Supplier/Vendor Supplier Company Name
Information
Address
Examples
ABC Ltd
1234 He Ping Rd
Dongguan, China
Tel/Fax/email
Tel: 12345678
Fax: 12345678
Email: wang jia@abc.com
Contact Person
Mr. Jia Wang
Product/component Sample description
Cable overmold
Quantity (numbers or weight)
10 pieces; 250 grams
Microsoft Product P/N
X01-12345
Microsoft Component P/N
C01-12345
Manufacturer P/N
M01-12345
Name of Component Vendor
China Plastic
Component Lot Number
MX-888-777-01
Country of Origin
China
Sample’s Photo
Digital Photo(s) of sample(s) after being
prepared
JPG embedded in each test
report
Analytical
Information
Sample preparation
Shaved
Test Method
Cd - EN 1122 and EPA 3050B
Pb – EPA 3050B
PQL and/or MDL
<2 ppm
Sample
Description
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APPENDIX B: Microsoft Restricted Substance Product Testing Form
APPENDIX B:
Microsoft Restricted Substance Product Testing Form.doc
APPENDIX C: Sample Shipping Instructions
When Suppliers and Tier 1’s submit samples for testing the following items are required to
identify and track the samples through the testing process:
1. testing application form,
2. sample list,
3. samples for testing.
When preparing the samples, prepare the shipment as follow:
 Ship products in the least number of boxes possible
 All associated batteries, adapters, cables, covers, carrying cases, etc. must be submitted
for testing.
Device/assembly Sample Size Instructions:
Device/assembly
Sample Size (Minimum)
Surface Pro, Laptop and Book
2
Power supply, cable, pen, mouse, keyboard,
camera and headset.
5
Surface desktop, Surface hub
1
Mainboard, HDD, Lithium battery and other
sub-assembly
2
Package Sample Shipping Instructions
You are required to submit testing application form, sample list and samples. Sample
preparation procedure is as follow:
 Prepare package sample by part number (e.g. SKU or top-level part number)
according to sample size instruction as above
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
All associated batteries, adapters, cables, covers, carrying cases, etc. must be
submitted for testing.

Submit each SKU or top-level part number in separate bag

Number each bag clearly

A sample list is required if there are more than five materials. This list includes sample
description, SKU or top-level part number, and bag number.

If multiple colors or versions of the same product exist, submit one representative
sample and the different parts only. E.g. if a product comes in three different colors,
submit complete product in one color and only the plastic casings for the remaining
colors.

Product packaging and print materials are required, only when requested by the
Microsoft Environmental Compliance Engineer. If packaging is requested only
representative samples need be submitted, e.g. one representative retail box, manual,
etc.
Packaging Part Sample Size Instructions:
Material
Sample Size
Carton, corrugated box, plastic case
5pcs/10g
Plastic tie, fastener, disk cover, software paper
cover, manual
10pcs / 10g
Foam, polybag, plastic film, label
20pcs~50pcs / 10g
Paint and ink
50ml of ink
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APPENDIX D: Nickel Plating Application Examples2
Surface
Application / Use
Substance
Requirement
HSC or HSC
Wearable
Examples:
No Nickel
plating
permitted, this
includes Nickel
under-plating








HSC N/A
Headset
surfaces
Xbox controller
buttons
Mobile phone
and tablet outer
covers and
enclosures
Mice top
enclosure
Mice buttons
Keyboard top
enclosures
Stylus
Game
controllers
Examples of areas not in
prolonged skin contact
per Microsoft:





Screws and
other fixtures
Metal sheets
and other parts
Plugs, pins,
connectors (not
accessible
during normal
use),
batteries
USB shrouds
Example surfaces and products
Nickel plating is
permitted
Do not need to
follow HSC
procedures.
2
EN 1811 testing is required to approve stainless steel in HSC applications.
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