Modern HDDs have spare sectors. When a sector is difficult to write, the drive marks it as "pending." During a zero-fill, the drive tries to reallocate it. If the spare sector pool is exhausted (Reallocated Sectors Count > manufacturer threshold), the drive returns a format error.
For drives with firmware bugs that prevent writing beyond a certain offset (common in some external USB drives with SMR technology), you may need to: hdd low level format tool format error occurred at offset
Drive: ST31000340AS (1TB) Progress: 94% Status: Format error occurred at offset 0x4A3F2B1C. Modern HDDs have spare sectors