Materials Use
Materials Leadership
Responsible Actions
Dell believes that if reasonable scientific grounds indicate that a substance or group of substances could pose significant environmental or human health risks, it is a substance of concern. Dell will avoid using these substances of concern and will take precautionary measures if these substances:
- Are a known threat to human health or the environment
- Show strong indications of significant risks to human health or the environment
- Are known to biopersist or bioaccumulate in humans or the environment
For more information on Dell’s precautionary approach to chemical management, please see Dell’s Chemical Use Policy. ![]()
The Company's Precautionary Measures
To enforce the company’s precautionary measures, Dell strives to eliminate substances of concern in its products by:
- Maintaining a Banned and Restricted Substance program
- Choosing designs and materials that avoid the use of substances of concern
- Prohibiting supplier use of these substances contractually
- Substituting viable alternative substances
If alternatives are not yet viable, Dell works with its industry partners to promote industry standards and the development of reliable, environmentally sound and economically scalable technical solutions.
Consistent with our Chemical Use Policy, periodic revisions of our restricted materials list will be made to incorporate legal requirements, relevant aspects of international treaties and conventions (such as the Convention for the Protection of the Marine Environment of the North East Atlantic Chemicals for Priority Action), and specific market demands.
Dell's Restricted Materials Guidance Document
This document lists substances that Dell bans or restricts. For each listed substance, a threshold limit has been established to account for unavoidable impurities along with exemptions consistent with regulatory requirements. Dell has implemented robust compliance assurance processes to ensure Dell's precautionary chemical use policies are met throughout the entire supply chain.
This document has been incorporated into Dell engineering specifications and supplier contractual agreements.
In addition, Dell has implemented process controls and corrective actions throughout its organization and supply chain to ensure that its chemicals-management objectives are met — and that the targeted restricted materials are replaced and alternative materials are developed for future product generations. Process controls that Dell implemented include piece-part supplier declarations and Dell factory and supplier material testing audits. Learn more about Dell's Restricted Materials Guidance Document.
Dell has implemented robust compliance assurance processes to ensure Dell’s precautionary chemical use policies are met throughout the entire supply chain.
Elimination of Brominated Flame Retardants and Polyvinyl Chloride
In line with Dell's Chemical Use Policy, the Precautionary Principle, and with consideration for Chemicals for Priority Action identified by the Convention for the Protection of the Marine Environment of the North East Atlantic (OSPAR), Dell's goal is to eliminate the use of all brominated flame retardant (BFR) chemicals and polyvinyl chloride (PVC) plastics in our products worldwide.
Brominated flame retardants and PVC are covered in Dell's banned and restricted materials program. For more information see Dell's Supply Chain Management and Compliance Process.
We currently avoid the use of BFRs and PVC by using plastics that can be flame retardant with non-halogenated compounds and by using design strategies that minimize plastics and therefore reduce the need to use flame retardant plastics at all.
Current BFR and PVC restrictions
- Dell currently prohibits the use of polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PDBEs,) including decabromodiphenyl ether (DecaBDE), for all applications.
- Dell currently prohibits the use of all other BFRs (including tetrabromobisphenol A [TBBP-A] and hexabromocyclododecane [HBCDD]) in plastic parts for desktops, laptop and server products as well as displays certified by the TCO (the Tjänstemännens Centralorganisation or Swedish Confederation of Professional Employees) and Blue Angel certified printers.
- Since June 2006, Dell prohibits the use of all BFRs in plastic parts.
Long Term Elimination Goal
Dell and industry partners are actively working to help the supply chain develop the capability and capacity to use viable alternative materials. These alternative materials are needed to realize our goal of eliminating all remaining uses of BFRs and PVC in our new products, including TBBP-A in circuit boards, in advance of regulation and as acceptable alternatives are identified. However, to be acceptable, any alternative materials must have a reduced impact on health and the environment without compromising product performance. We will continue to strive to meet our goal to eliminate the use of environmentally sensitive materials in our products, as well as continue to evaluate the viability of halogen-free flame-retardant alternatives.
Progress Toward Long Term Goals
Since 2006, Dell has been working to better understand supply chain readiness for BFR- and PVC-free electronics, to develop technology roadmaps and to qualify suitable replacement materials. The following key milestones have been met in recent months:
- Dell is currently leading industry consortia projects aimed at development of BFR/PVC-free technologies (within the Environmental Protection Agency, International Electronics Manufacturing Initiative and High Density Packaging User Group) and standards (within the Interconnecting and Packaging Electronic Circuits [IPC]).
- In an ongoing effort to eliminate the remaining uses of BFRs and PVC within our new products, the following ‘Halogen-Reduced’ products have been introduced:
- In January 2009, Dell announced the G-Series LED monitors that are free of PVC, BFR, chlorinated flame retardants (CFRs), arsenic and mercury. (Note: PVC/BFR/CFR-free cables available only in North America, Japan and Europe, the Middle East and Africa (EMEA), excluding Israel).
- Dell also offers a wide variety of Flat Panel Displays that contain multiple printed circuit boards containing halogen-free laminates per Japan Electronic Packaging and Circuits Association (JPCA) ES-01-1999, as well as halogen-free chassis plastics. These Flat Panel Display products include the Dell UltraSharp 2009W, SP2009W, E2009W, E2209W, SP2309W and the UltraSharp 1909W.
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Dell’s Studio Hybrid was the first halogen-reduced Dell desktop that contains a motherboard using “halogen-free” laminates, as well as halogen-free chassis plastics.
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Dell’s Latitude E4200 laptop contains a motherboard using halogen-free laminates, as well as halogen-free chassis plastics. Additionally, the system fan housing and impeller are constructed using halogen-free plastics, significantly reducing the overall weight of halogenated plastics in this product.
Challenges in the Elimination of BFR
In 2008, Dell removed our 2009 BFR- and PVC-elimination deadline due to lack of viable, high-volume BFR- and PVC-free alternatives within the global supply chain. Dell and industry partners are actively working to help the supply chain develop the capability and capacity to use viable BFR- and PVC-free alternative materials.
Today, there are limited BFR- and PVC-free solutions that have been qualified for all high-volume applications across all IT products, in particular the components and cables that are the basic building blocks for IT equipment. As these are standard parts that are used across the IT industry, Dell has initiated projects in major trade associations (such as International Electronics Manufacturing Initiative and High Density Packaging User Group) to help develop viable solutions and enable supply chain conversions.
Arsenic-Reduction Initiative
Mercury-reduction Initiative
Dell plans to transition all of its new laptop displays to light-emitting diode (LED) by 2010. In addition to the energy savings when compared to cold cathode fluorescent lamp (CCFL), LED displays technology eliminates the use of mercury commonly found in CCFL. This technology has already been incorporated in the Dell Latitude E4200, E4300, E6400, E6400 ATG and E6500 and Dell is committed to expand the list of mercury free, LED-based products in future offerings. Learn more about the Mercury Reduction Initiative.
Lead-Free Enterprise Product Transition
When the exemption expires per EU regulatory process, Dell is committed to complying with the European Union (EU) Restrictions on Hazardous Substances (RoHS) Directive’s prohibition on lead in solders for servers, storage and networking equipment. In early 2007 we established a lead-free enterprise team to manage the transition across our enterprise product lines. As part of this transition, the team defined a lead-free solution that was qualified across our supply base. We have demonstrated that our solution addresses the major issues associated with lead-free technology. Dell has launched multiple displays (E207WFP, E1909W, E1909WDD, E2209W, E2009W G2210 and G2410) that contain 25 percent post-consumer recycled plastic and one desktop, the OptiPlex 960, that features 10 percent post-consumer recycled plastic content. In 2008, we shipped more than 1.1 million pounds of post-consumer recycled plastic, recycling more than 3 million water bottles. This volume is projected to increase in 2009. Regulations The list of world-wide legal and market material regulations is lengthy and constantly changing. Here are several of the more commonly requested declarations and certifications. EU RoHS: In 2006, the EU Restriction of Hazardous Substances (EU RoHS) Directive went into effect. The directive restricts the use of cadmium, hexavalent chromium, lead, mercury and certain halogenated flame-retardants (PBBs and PBDEs) in electronic products. Dell has voluntarily adopted the requirements of the directive globally to help eliminate waste, conserve energy and reduce environmentally sensitive materials. Learn more about EU RoHS. EU REACH: Dell aims to satisfy all Registration, Evaluation, Authorisation and Restriction of Chemical substances (REACH) requirements and is committed to provide our customers with information about substances in our products according to future REACH requirements. View the full REACH statement. EU REACH requires Dell to provide customers with sufficient information on Substances of Very High Concern (SVHC) contained in products in concentration above 0.1% weight by weight (w/w) to allow safe use of the product. Please refer to the Dell REACH SVHC Table for additional details. China RoHS: On February 28, 2006, the People’s Republic of China released a regulation called “Management Methods for Controlling Pollution by Electronic Information Products,” commonly referred to as China RoHS. China RoHS restricts the same six substances as the EU version. In addition, producers must also properly label and disclose RoHS information for applicable Electronic and Information Products (EIP) and parts sold in China. All Dell products shipping directly into China which were manufactured on or after March 1, 2007, are China RoHS compliant. California SB20: The State of California has passed legislation instituting a mandatory State Environmental Fee be collected for certain electronic products shipped directly from Dell to California. Learn more about the California SB20. Emerging Chemicals Management Strategies The substitution of chemicals can affect the entire product life cycle; it is critical to thoroughly evaluate the environmental and human health aspects of currently used chemicals and candidate substitution chemicals. Dell has recently engaged stakeholders such as Clean Production Action (CPA) to develop principles and assessment tools that effectively promote and develop the use of environmentally preferable chemicals across the entire life cycle. One aspect of our strategy is to understand where and in what concentrations we can use certain substances. In fiscal year 2009 Dell will begin requesting supplier disclosure of the Joint Industry Guide (JIG) Level B substance list and additional substances that are likely subject to EU REACH disclosure requirements. Substances such as antimony compounds, beryllium compounds, phthalates and bisphenol-A are included in the JIG Level B list. Verifying Supplier Compliance Dell requires suppliers to sign a Supplier Declaration of Conformity (SDoC), modeled after ISO/IEC 17050-1, to ensure that all product materials comply with Dell’s chemical policy. This documentation is required for the release of parts into production. A signed SDoC indicates that a product meets the Dell Materials Restricted for Use specification and records any applicable exemptions. Dell may request additional technical documentation such as internal design controls, supplier declarations or analytical test data. Our objective is to collect supplier declarations for each part in a product’s bill of materials. Figure below shows the compliance verification process for our suppliers. A second tier in our compliance verification strategy is our supplier RoHS audit program, which includes a traditional audit and an in-depth supplier survey.
Dell launched the industry’ first RoHS-compliant lead-free server products, the M-Series Blades, in January 2008. Dell continues to launch lead-free and lead-reduced RoHS-compliant enterprise platforms ranging from tower servers to high-end 4-socket rack server and storage systems. Many Dell servers are now available in a RoHS-compliant lead-free configuration. As part of our commitment to the environment, we will increase our selection of servers in RoHS-compliant lead-free configurations and will continue to anticipate and meet future RoHS requirements across our entire enterprise portfolio. Post-consumer Recycled Content Plastics