Pigments, inks, dyes, and other colorants that are present at or above the selected Threshold(s) in the Content Inventory are required to be reported on an HPD.


There has historically been a lot of variation in how product manufacturers report colorants on HPDs. The following guidance has been developed to ensure more consistently. This guidance will be formally included in HPD v2.3, which will be released in 2020. HPDC is offering this guidance now as a clarification of best practices.

  • For products with some colorant substances being used in only one or a few products or product types, and/or being used at varying percentages, list individual colorant substances with a percent weight from 0% to a maximum percentage, with an explanation provided in the Substance Notes. 
  • The maximum percentage of any colorant substance possible in any of the product variations covered by an HPD must be considered and reported in the Content Inventory if it is at or above the selected Threshold(s). 
  • Substances in addition to the pigment itself, such as solvents, carriers, and fillers, must be considered and reported in the Content Inventory if they are at or above the selected Threshold(s).


For products, such as paint, that are formulated and produced as a base product, it may not be feasible to report the full range of possible colorant substances, particularly when they are added by different suppliers in the product distribution process. Manufacturers in this situation may take the following approaches:

  1. Complete an HPD for the base, untinted product, and/or
  2. Complete one or more HPDs for tinted product(s) [see 3.1.4 Products Composed of Combinations of Parts].


For either approach, the following steps are required:

  • In Product Name, include an appropriate term to indicate the scope of colorants, such as “Base,” “Untinted,” “Red Color Family,” “Barn Red,” etc.
  • In Product Description, include additional brief description of how colorants were or were not reported in the HPD.

If you have any questions on how to report colorants in a product, contact HPDC customer support via this portal!