Document o9Lpzvz700NnxzbRQR6ro0Y07

ESIA (- u r o p e a n S e rn I c o n d u c t o r I n d u s t r y A s s o c i a t I o n - Ref.Ares(2022)5318093.22/07/2022 PFAS in the semiconductor industry Meeting with F.1 REACH ESIA ESIA Members @ BOSCH lllleC embracinga better life FONDAZIONE BRUNO KESSLER F fj 'lim Fachvc,t>and de, Clektro und tekuonikindustrie intel. ne><per1a Fraunhofer MIKROElEKTRONIK !II Globalfoundries ::\ ::. : .S .:. ;:-iJ LFOUn:::>V Solutions for greatvisions ENESAS s:itec Hie.augmented TDK ,lj TEXAS INSTRUMENTS xJab ZVE:I: Die Elektroindustrie ESIA The voice of the semiconductor industry in Europe Represent the interests of the European-based semiconductor industry and advocate for its international competitiveness. most R&D-intensive sector highly-developed global supply chain fierce competition & price fluctuation short in novation cycles multiplier for growth, electronics boost innovation global market estimated at$ 556 billion in 2021 (+26.2% yoy) Europe strongest market for automotive (29%) EU ea. 10% of global market direct employment 200.000 indirect up to 1.000.000 ESIA is member of the World Semiconductor Council (WSC) ESIA PFAS i n the SC industry PFAS are used in low concentrations in Specialty formulations in different SC . Constituentof manufacturing processes, such as specialty process chemistry formulations photolithography due to their high (photolithography, technical functionality chamber clean/etch, and other mixtures) PFCs are used for etching Direct criticality >13 types of distin Photolithography and etching are the uses/ material functionalities fundamental basis of SC manufacturing, making PFAS/PFCs critical for continued . Fluoropolymersin SC manufacturing and innovation in articles(component, Europe 1r :;i:::d:, :ries, The SC industry will need to obtain insulators, capacitors,..) appropriate derogations for PFAS Sem iconductor manufacturing equlpment (HTFs) Fluoropolymer artic es In manufacturingeq uipment and chemical distributon systems (filte rs, tu bing, linings, o-rin gs, etc.) Factory infrastructure 'Fabs' Fluoropolymerarticlesin water purification, chemicaldelivery and waste management systems (tank and duct linings, plpes,etc.) ESIA PFAS in the SC industry No feasible alternatives have been invented Technical feasibility to support critical performance are key attributes of any feasible alternative It is envisaged that it will take 1 O+ years to qualify and implement in practice non-PFAS alternatives with the same technical properties, after such an alternative has been invented. For some applications, an alternative might never be invented 7 Fundamental Research and Invention C: f ,!:: supp_!!er R&D Ramp to Production Manufacturing ',,=...;.:,;r Years 10+ 8 6 4 2 0 . R&D Exempti ESIA Risk Management in the SC Industry Stringent risk management measures and safety practices to prevent release of chemicals during all stages of manufacturing No release to the workplace environment during normal production Closed system manufacturing equipment installed in a clean room Automated chemical delivery systems create barrier between highly skilled workers and manufacturing process, protecting against chemical and physical hazards ESIA PFAS Consortium The industry and its key suppliers have formed a Semiconductor PFAS Consortium to collect the technical data needed to better understand PFAS use in our industry and inform policy development, including: Developing concepts by applying the pollution prevention hierarchy, where possible: to reduce consumption or eliminate use of PFAS containing specialty materials, to identify alternatives for PFAS containing specialty materials, and to minimize and control emissions of PFAS Identification of research needs, and Development of socioeconomic impact assessments The consortium membership includes semiconductor manufacturers and members of the supply chain including chemical, material and equipment suppliers ESIA The way forward Projects that are already in the public domain Horizon Europe membrane distillation application (more information available here) Semiconductor Research Corporation US-based, includes ESIA member companies Collaboration between SC industry and academia More information available here SC industry is prepared to invest more into R&D on PFAS SC manufacturing: PFAS as a process chemical Emissions: Minimize PFAS release ESIA PFAS and the SC supply cha in PFAS consortium has helped get the supply chain engaged in PFAS efforts SC supply chain is global and consequently vulnerable to disruptions Compared to SC industry in other regions where PFAS is not regulated, the European SC industry would be placed as a competitive disadvantage ESIA PFAS and the F-Gas Regulat ion The F-Gas Regulation has been the one-stop-shop for F-Gases and has been successful in reducing emissions Taking certain F-Gases out of the scope of the F-Gas Regulation and including them in the REACH restriction will cause disruptions F-Gases for servicing and maintenance of refrigeration equipment Now: Equipment with charge size of >40t CO2(e) banned starting 2030 Proposal removes differentiation of equipment with <40t of CO2(e) charge size Renders semiconductor chiller fleet obsolete in 2030 Quantity in each chiller is low, number of chillers is high, overall amount of refrigerant is small and potential loss of refrigerant is low Strict measures in place to minimize fugitive emissions Potential environmental benefit is negligible compared to the resources required to qualify new gases ESIA Questions to the Commiss ion Extension of REACH Restriction Derogations PFHxA REACH Restriction process is well underway In the RAC and SEAC background documentation, it was noted that an extension to the 12-year derogation for the semiconductor industry is only justified when manufacturers proviqe rtiore detailed information on substitution efforts and prepare detailed subst1tut1on plans What would such a review process look like for an extension of the derogation? The legal aspect of the Essential Use Concept will not be part of the proposed REACH Restriction on PFAS Nonetheless, essentiality will be used to some extent in the PFAS Restriction. How will that work? The final RAC and SEAC opinion on the restriction of PFHxA uses a definition of "Semiconductors and semiconductor related equipment". Is it fair to assume that this also covers semiconductor manufacturing equipment? ESIA Thank you for your attention! http://www.eusemiconductors.eu/ Twitter : @eSemiconductor Linkedln: European Semiconductor Industry Association