HP Supplier Sustainability Requirements: A Guide to Carbon Emissions Reporting

HP is one of the largest technology companies in the world, and has set ambitious expectations for suppliers on carbon measurement, reporting and reduction. It was the first global IT company to publish its full carbon footprint. Since then, HP has committed to achieving Net Zero greenhouse gas emissions across its entire value chain by 2040. As part of this ambition, it has set a science-based target to cut absolute Scope 1, 2 and 3 emissions by 50% by 2030 against a 2019 baseline. A significant proportion of HP’s emissions sit across its supply chain, which is why the emissions its suppliers measure, report and reduce matter so much to hitting those targets.

If you sell goods or services to HP, that ambition reaches you through a set of contract terms, not a friendly request. HP's Supplier Code of Conduct and its General Specification for the Environment are named, binding parts of the agreement you sign to do business with HP. They carry a specific carbon obligation: track your energy use and emissions, set an absolute company-wide reduction goal, and report the data, publicly and to HP. Getting this right has an upside beyond compliance, because HP says it gives preference to suppliers that meet or exceed its expectations when it awards and retains business. This guide covers what HP asks for, which documents create the obligation, who is in scope, and how the reporting actually works.

What are HP's environmental expectations for suppliers?

HP’s Supplier Code of Conduct covers a range of responsibilities, from labour and human rights to health and safety and business ethics. Section C sets out its environmental expectations, covering areas such as waste, hazardous substances, water, emissions and environmental permits. Carbon is just one part of this broader set of obligations. This guide focuses on emissions, which is often one of the most challenging areas for suppliers. HP expects suppliers to have a credible greenhouse gas reduction strategy covering their global operations, not just the work they do for HP. 

According to HP, a credible strategy has three elements:

• A corporate-wide GHG inventory covering Scope 1, 2 and significant Scope 3 emissions, built in line with the GHG Protocol and ideally third-party reviewed or assured, reported to HP each year.
• A current, publicly announced, corporate-level GHG emissions reduction goal, set on an absolute basis (HP encourages science-based targets aligned with the SBTi).
• A commitment to keep improving emissions performance over time.

Alongside this, HP asks suppliers to take part in its environmental improvement projects where requested, such as its Energy Efficiency Program, and expects energy use and emissions to be tracked, documented and reduced at source wherever it is cost-effective to do so. The thread running through all of it is measurement first. You cannot set a credible reduction goal, or show progress against it, without an accurate footprint underneath.

Which documents set out HP's supplier requirements?

This is where the "binding, not optional" point becomes concrete. HP's requirements are spread across several documents, and signing up to them is a condition of doing business with HP. The ones that matter most for carbon are below.

Two labour-focused standards, HP's Student and Dispatch Worker Standard for facilities in China and its Supply Chain Foreign Migrant Worker Standard, also form part of the stack where applicable, though they sit outside the carbon remit this guide focuses on.

Are HP's supplier requirements binding, or just guidance?

They are binding. HP builds these documents into its contracts and purchasing agreements, and the Supplier Code of Conduct is explicit that complying with it is a condition of doing business with HP. HP assesses suppliers against the Code through self-assessments, on-site audits (announced and unannounced) and focused assessments, carried out by HP or third-party auditors. Where a supplier does not conform, HP can require corrective action, and, in its own words, non-conformance may result in the suspension or termination of the contractual relationship.

There is also a knock-on effect worth flagging. HP treats the Code as a total supply chain initiative, so suppliers are expected to pass the same expectations down to their own next-tier suppliers, and to show reasonable due diligence across their supply chain on request. 

Who needs to report carbon data to HP?

Broadly, any supplier. HP defines a supplier as any party that provides goods or services for HP's internal use or in connection with a product HP sells, provides or markets. That takes in manufacturers of products, parts and packaging, service providers of all kinds (wherever the service is performed), and subcontractors further down the chain.

That said, the requirements are applied proportionately. The full weight of the environmental improvement projects lands on manufacturing and higher-impact suppliers, while the core carbon expectations, a footprint, a reduction goal and honest reporting, are framed to apply across the supplier base. If HP is a customer, the safe assumption is that you are in scope for the carbon reporting expectations, and the sensible step is to confirm exactly what applies to you rather than assume you are too small or too service-based to count.

What data do HP suppliers need to report? 

The emissions reporting obligation is written into Section C.8 of the Code, and it is specific about what suppliers have to track and disclose:

• Energy consumption, tracked and documented.
• All Scope 1 and Scope 2 emissions, plus the significant categories of Scope 3.
• An absolute, corporate-wide GHG reduction goal, reported against and publicly disclosed.

In practice, then, the ask is a full-scope, GHG Protocol-aligned footprint, backed by activity data, sitting behind a public absolute reduction goal you can show progress against year on year. The word "absolute" matters. HP asks for a goal that reduces your total emissions, not just your emissions per unit of revenue or output, which is a higher bar than an intensity target alone.

Beyond the Code, HP requests a wider environmental data set from suppliers, which typically includes:

• Scope 1, 2 and 3 GHG emissions
• Electricity usage and renewable-energy usage
• Water consumption, recycling and discharge
• Hazardous and non-hazardous waste generation
• Reduction goals for emissions, energy, water and waste

How do HP suppliers report their emissions?

This is the part suppliers most often get stuck on, because it runs through the RBA rather than an HP-branded portal.

• Annual GHG reporting through RBA-Online. HP asks suppliers to report their corporate-wide GHG inventory to HP each year through the RBA-Online (RBA-ON) tool, the shared data platform HP and other RBA members use to collect supply chain emissions data.
• The RBA Self-Assessment Questionnaire (SAQ). On request, suppliers complete the SAQ covering environment alongside labour, health and safety and ethics. HP reviews it and expects an improvement plan with defined timelines and metrics where gaps show up.
• Public disclosure. The Code requires the reduction goal and emissions to be publicly reported, so a supplier's own reporting channel (an environmental report, website disclosure or equivalent) matters too, not only the data shared privately with HP.
• Assurance. HP states the GHG inventory is ideally third-party reviewed or assured. It is not framed as mandatory in the way some buyers require it, but an assured inventory carries more weight and reduces the risk of questions later.
• Audits and sign-off. Suppliers review and sign HP's SER Agreement, cooperate with periodic on-site audits and assessments, and provide clear, accurate reporting throughout.

The quality of your underlying data does a lot of work here. A footprint built mostly on spend-based estimates will give you a headline number, but it is a weak basis for a credible, publicly reported reduction goal, because spend rarely tracks the real changes you make to cut emissions. Activity-based data, real energy use, material weights, distances travelled, gives you a footprint that moves as you decarbonise, which is the whole point of setting a goal in the first place.

What is the RBA, and how does it fit in?

The Responsible Business Alliance is the electronics industry's responsible-supply-chain body, founded in 2004 by a group of leading electronics companies. HP's Supplier Code of Conduct is based on the RBA Code of Conduct, which is why so much of HP's process, the SAQ, the audits, the reporting tool, sits within the RBA's system rather than HP's own.

For carbon specifically, the RBA runs an Emissions Management Tool (EMT) to help suppliers track and share Scope 1, 2 and 3 emissions data with customers. It has also published Scope 3 Category 1 (purchased goods and services) guidance with the Global Electronics Association, reflecting the fact that purchased goods are typically the largest source of emissions for electronics companies. If HP is your customer, you are effectively plugging into this shared infrastructure, and understanding that upfront saves a lot of confusion when the data request lands. The same pattern, a large buyer pushing carbon reporting down its supply chain, is one Microsoft and Apple apply too.

How does emissions reporting work through the RBA tools?

The RBA's platforms are where HP collects your data, not where your footprint gets built. The tools assume you arrive with the numbers already worked out.

• The SAQ (in RBA-Online) asks whether you track emissions, have a reduction goal, and manage energy and resources. It records what you have in place, and does not calculate anything for you. It is renewed every 12 months.
• The Emissions Management Tool (EMT) is where the figures go. It stores your Scope 1, 2 and 3 data, your reduction targets, and the verification status of your inventory. It expects a complete, structured footprint, not raw data.
• Verification happens first, separately. You record whether your inventory has been assured, but the assurance itself is arranged before anything is uploaded.

In short, the RBA tools reward suppliers who turn up with a clean, fully calculated, ideally assured footprint. The real work happens before you open them.

What are the key dates for HP suppliers?

HP does not set a single fixed reporting deadline. Instead, obligations are triggered promptly on HP's request, the GHG inventory is reported annually on HP's own cycle, and the SAQ lapses after 12 months, so reporting is a recurring commitment rather than a one-off. Underneath that annual rhythm sit HP's own milestones, which shape how demanding the ask becomes over time.

As HP works towards a 50% absolute cut this decade and Net Zero across its value chain by 2040, the expectation on suppliers to provide accurate, activity-based, ideally assured data only grows. 

What are the benefits of reporting carbon data to HP?

Reporting well is worth more than staying compliant. HP states plainly that, in selecting and retaining suppliers, it shows preference to those that meet or exceed its expectations. Carbon reporting is not a box-ticking exercise filed under compliance; it is one of the criteria that can influence whether you win and keep the account. A supplier that turns up with an accurate, assured footprint, a genuine reduction goal and evidence of progress is easier to keep in the supply chain than one scrambling to produce a number each year.

There are wider gains too. The same footprint you build for HP does the work for other customers asking similar questions, for frameworks like CDP and EcoVadis, and for SECR or B Corp if they apply to you. And the reduction goal HP asks for is the same one that cuts your energy bills as you act on it. Done properly, reporting to HP is less an overhead and more a piece of infrastructure you reuse.

How should HP suppliers prepare?

If HP is a customer, or you are bidding to become one, a sensible sequence looks like this:

• Confirm what applies to you. Check whether you are a product or materials supplier (in scope for the General Specification for the Environment as well as the Code), a service supplier, or a subcontractor, and what that means for your obligations.
• Build a full-scope inventory in line with the GHG Protocol, covering Scope 1, Scope 2 and the significant Scope 3 categories, using activity data wherever you can.
• Set an absolute reduction goal, corporate-wide, that you can publicly state and report against.
• Get the wider data ready. HP asks about renewable electricity, water and waste alongside emissions, so pull those together in the same exercise.
• Consider assurance. An independently reviewed or assured inventory carries more weight with HP and reduces the risk of challenge.
• Treat it as an annual cycle. The first year is the heavy lift. Once the groundwork is in place, each subsequent report is faster and cleaner.

How Seedling can help

This is the kind of work we handle every day. Seedling combines carbon accounting software with one-to-one support from a dedicated carbon expert, so you are not left to interpret a customer's requirements on your own. For suppliers facing HP's requirements, we can help you:

• Build the inventory. A full-scope, GHG Protocol-aligned footprint across Scopes 1, 2 and 3, built on activity data rather than spend estimates.
• Assure your footprint. HP prefers an assured inventory, and Seedling assures every footprint we produce, so your data stands up to scrutiny.
• Set an absolute reduction goal. A credible, SBTi-aligned target and a data-backed plan to reach it, so you have progress to show, not just a number.
• Report year after year, with less effort. Your data stays in one place, so each annual cycle means updating the numbers and showing reductions against target, not starting over.
• Signal your credibility. Share your results through a public impact page, or go further with Seedling Certification to show your strategy has been expert-checked.

We do similar work for businesses reporting to other major customers, including helping Janea Systems report their carbon data to Microsoft. The principle carries across: a solid, activity-based inventory, a credible reduction goal, and the documentation to back it up.

If you would like to talk it through, you can book a demo or get in touch with the team.

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