Electronics include circuit boards, displays, and related wires and connectors. Electronics comprising 10% or less of a product by weight are addressed by this Special Condition. If electronics comprise greater than 10% of the product by weight, they must be inventoried separately. The electronic components must be fully enclosed and sealed, there can be no possible exposure to the components during the use phase, and there must be a guaranteed take-back program.


While in theory a content inventory can be created with current HPD methods, it may not be practical to do so, especially when they are only a small part of the overall product. Electronics are highly complex mixtures of materials and substances with a long and complicated supply chain, and inventorying them at the level expected for other contents may be difficult or impossible for a product manufacturer.


Manufacturers noting an electronic component in a product can use the identifier “SC:Electronics” to refer to the Special Conditions guidance. They should also:

  • Enter a brief description of the component or part (including its function).
  • Indicate if the component or part is compliant with the most recent EU RoHS directive.
  • Include a statement that the component is included in a takeback program.


This is just a summary; detailed information is available in HPDC’s Emerging Best Practices guidance.