Document rpqyBqyveYY3QXy67ONoezBVq

semr - Ref. Ares(2021)6413622- 19/10/2021 SEMI Europe Rue de la Science 14 1040, Brussels s!,e,: m== 1eu=ro=p""" e@= sem1.org www.semiorg European Commission DG Environment Avenue de Beaulieu 9 1160, Brussels Subject: SEMI Stockholm Convention PFOA Recommendations Dear SEMI is very grateful for the consideration the POPRC has given in the past to our recommendations for specific exemptions to a listing of PFOA in Annex A. Since the time of our last communication with the POPRC, we have been studying our equipment components and related supply chains more closely, and have reconsidered the draft exemptions which address new and legacy equipment and fabrication plant-related infrastructure (and related refurbishment parts) for the manufacture of semiconductors and related electronic devices, specifically focused on fluoropolymers and fluoroelastomers which might contain PFOA as an impurity or unintentional residue. We now understand that any PFOA that might be present in fluoropolymers or fluoroelastomers used in our sector is present only as an unintentional contaminant or impurity, and serves no intended purpose or performance function in the materials used in products for our sector. We also understand that the anticipated concentrations of any such impurity in materials used in products and articles used in semiconductor manufacturing are very low. Therefore, we believe that these cases will be adequately addressed by the operation of the Convention's "unintentional trace contaminant" exemption (in Note (i) of Annex A and Annex B), and that no specific exemptions are required in order to accommodate the presence of such contaminants. However, the specific exemption points related to photo-lithography and etch processes should remain. The following shows our requested changes (strikethrough) in the context of the POPRC recommendation: POPRC-14/2: Perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds The Persistent Organic Pollutants Review Committee, Recalling its decision POPRC-13/2, by which it recommended to the Conference of the Parties that it consider listing perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds3 in Annex A to the Convention with specific exemptions as specified in paragraph 2 (a)-(c) of that decision; Having assessed the information provided in accordance with paragraphs 3 to 5 of decision POPRC13/2, semr SEMI Europe Rue de la Science 14 1040, Brussels s!,e,: m== 1eu=ro=p=-= e@= sem1.org www.semiorg Recognizing that a transition to the use of short-chain per- and polyfluoroalkyl substances (PFASs) for dispersive applications such as fire-fighting foams is not a suitable option from an environmental and human health point of view and that some time may be needed for a transition to alternatives without PFASs, 1. Adopts the addendum to the risk management evaluation for perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds; 2. Decides, in accordance with paragraph 9 of Article 8 of the Convention, to recommend to the Conference of the Parties that it consider listing perfluorooctanoic acid (PFOA), its salts and PFOA-related compounds in Annex A to the Convention with specific exemptions for the following: (a) For five years from the date of entry into force of the amendment in accordance with Article 4: (i) Manufacture of semiconductors or related electronic devices: r: l!q1:1ipFF1eRt e r fabrieatieR plaRt relatee iRfrastr1:1et1:1re eeRtaiRiRffi aReer fl1:1ereelasteFF1ers with FIFO/I, resie1:1es, - begaey eqfiRt er legfiY fabrieatieR relatee iRfrastr1:1et1:1re: mteRaRee; c. Photo-lithography or etch processes; (ii) Photographic coatings applied to films; (iii) Textiles for oil and water repellency for the protection of workers from dangerous liquids that comprise risks to their health and safety; (iv) Invasive and implantable medical devices; (v) Fire-fighting foam for liquid fuel vapour suppression and liquid fuel fires (Class B fires) already in installed systems, including both mobile and fixed systems, taking due account of the possible related control measures specified in the annex to the present decision; (b) Fer teR years fr8Ffl the eate efeRtry iRte fereeefthe aFF1eReFF1eRt fer FF1aRl:lfaet1:1re ef seFF1ieeRe1:1eters er relatee eleetreRie eet,iees: ref1:1rbishFF1eRt parts eeRtaiRiRg f11:1erepelyFF1ers aReer fl1:1ereelasteFF1ers with FIFOAresie1:1es fer le eq1:1ipFF1eRt e r legaey ref1:1reishFF1eRt ; (c) For use of perfluorooctane iodide, production of perfluorooctane bromide for the purpose of producing pharmaceutical products w ith a review of continued need for exemptions. The specific exemption should expire in any case at the latest in 2036; 3. Recommends to the Conference of the Parties that it consider encouraging Parties not to replace fire-fighting foam that contains or may contain PFOA, its salts and PFOA-related compounds with short-chain PFASs due to their persistency and mobility as well as potential negative environmental, human health and socioeconomic impacts. semr SEMI Europe Rue de la Science 14 1040, Brussels s!,e,: m== 1eu=ro=p=-= e@= sem1.org www.semiorg We hope this will help simplify your efforts at the upcoming Conference of Parties. President, SEMI Europe [Director of Pullie Policy, SEMI Europe About SEMI: SEMI represents more than 2,200 member companies to advance the technology and business of electronics manufacturing. SEMI members are responsible for the innovations in materials, design, equipment, software, devices, and services that enable smarter, faster, more powerful, and more affordable electronic products. Electronic System Design Alliance (ESD Alliance), FlexTech, the Fab Owners Alliance (FOA) and the MEMS & Sensors Industry Group (MSIG) are SEMI Strategic Association Partners, defined communities within SEMI focused on specific technologies. Since 1970, SEMI has built connections that have helped its members prosper, create new markets, and address common industry challenges together. SEMI maintains offices in Bangalore, Berlin, Brussels, Grenoble, Hsinchu, Seoul, Shanghai, Silicon Valley (Milpitas, Calif.), Singapore, Tokyo, and Washington, D.C. For more information, visit www.semi.org. Contact: Public Policy, SEMI Europe @semi.org