Document wDxeBL3GVjzB8w4QZ5dr5zqm6

ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process" 20:09:2023 [Double-click to import picture] ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process CONTENTS CONTENTS 1. EXECUTIVE SUMMARY .............................................................................................................. 1 2. BACKGROUND INFORMATION ................................................................................................. 3 2.1 Regulatory background on PFAS .................................................................................................. 3 2.2 Information on the stakeholder ...................................................................................................... 4 2.3 Aim of the report ............................................................................................................................ 4 3. USES OF PFAS IN THE SEMICONDUCTOR MANUFACTURING PROCESS - DESCRIPTION OF MOST IMPORTANT USES .................................................................................................... 4 3.1 Use in the Photolithography, wet etching of silicon dioxide coatings and plasma etching. ............ 4 3.2 Use in Cleaning of the plasma deposition chambers. .................................................................... 5 3.3 Use in Working fluid for vacuum pumps......................................................................................... 5 3.4 Use in Lubricants ........................................................................................................................... 5 3.5 Use in Manufacturing equipment. .................................................................................................. 5 3.6 Use in Wafer containers................................................................................................................. 5 3.7 Use in Heat transfer fluids.............................................................................................................. 5 3.8 Use in Refrigeration of Clean Rooms and production equipment. ................................................. 6 3.9 Use of PFAS in various components used in the production process............................................ 6 3.10 Use of PFAS in the finished semiconductors ................................................................................. 6 4. VOLUMES OF PFAS IN SEMICONDUCTOR MANUFACTURING PROCESSES..................... 6 5. EMISSIONS .................................................................................................................................. 8 5.1 Production process ........................................................................................................................ 8 5.2 End-of-life of finished products ...................................................................................................... 9 6. ANALYSIS OF ALTERNATIVES ................................................................................................. 9 7. SOCIOECONOMIC IMPACT ASSESSMENT............................................................................ 10 7.1 Market overview and downstream products................................................................................. 10 7.2 Wider socioeconomic impact ....................................................................................................... 10 7.2.1 7.2.2 7.2.3 EU Chips Act .............................................................................................................. 11 EU's Net-Zero Industry Act - EU decarbonisation goals............................................. 11 EU circular economy action plan................................................................................. 12 8. CONCLUSION AND PROPOSAL FOR PUBLIC CONSULTATION......................................... 13 List of Tables Table 1 Volumes of PFAS used in semiconductors manufacturing at ams OSRAM.............................. 7 ams-OSRAM AG Page i ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process EXECUTIVE SUMMARY 1. EXECUTIVE SUMMARY ams-OSRAM AG and affiliated companies (ams OSRAM) produces light emitters, optical components and modules, light sensors and associated integrated circuits (IC). With more than 21000 employees worldwide, ams OSRAM is one of the global leaders in the LED and sensor markets. ams OSRAM products are used in a variety of industrial applications and consumer products. The use of microLEDs produced by ams OSRAM improve energy efficiency of the downstream products while reducing emissions and use of resources. ams OSRAM welcomes the opportunity to submit a response to the public consultation of the EU PFAS (Per- and polyfluorinated alkyl substances) proposed restriction This report provides information on PFAS used in its manufacturing processes, their products containing PFAS, and the estimated volumes used. In addition to any available information from our productions processes, this report provides a summary on some of the efforts of other semiconductor manufacturers to identify non-PFAS alternatives and the challenges to find suitable alternatives. Finally, we also report information on the risk reduction measures for PFAS emissions during our manufacturing processes and, where possible, at end of life of the PFAS-containing products. In several steps of the semiconductor's production processes PFAS are used. They constitute an irreplaceable part of the production equipment or the final products. During the semiconductor manufacturing process hazardous, toxic, flammable, corrosive and/or highly reactive chemicals are used. Many of these processes are performed at high temperatures and/or in high vacuum conditions. That is why materials that are chemically inert and have high mechanical and thermal resistance are required. In most cases only PFAS fulfil these requirements. Furthermore, the PFAS materials used in the production of semiconductors do not release any contamination (as a particle or substance) that would compromise the manufacturing process. Approximately 8.5 t of PFAS are annually used in the production of semiconductors at ams OSRAM, according to the ongoing assessment on PFAS uses. More information is expected to be delivered by the suppliers. ams OSRAM is actively replacing PFAS in any use where alternatives exist and are available, such as in the use of methoxy-nonafluorobutane (C4F9OCH3) for the cleaning of the plasma etching chamber. However, as this report is being prepared, there are no PFAS-free material or chemicals, or alternative technologies that can be used to replace PFAS in most of the manufacturing uses. Upstream developers of the equipment used for semiconductor manufacturers and suppliers of chemicals used in the existing processes are continuously researching to improve their products, and part of that should research include replacements for the currently used PFAS, but their replacement is estimated to take between 4 to 10 years of implementation where alternatives have been identified. Where further R&D is needed to develop new alternative substances or entirely new processes, the estimated required time is more than 25 years. The emissions of PFAS during the production processes are being actively managed and minimized. Best available technologies are used to treat any emissions produced during the production process. ams OSRAM products and downstream applications contribute to several strategies of the EU, such as the EU Green Deal and the EU Digital Strategy. Many of these products play a key role in the implementation of several policies such as the EU Chips Act, the EU's Net-Zero Industry Act, The Digitalisation of the European Energy System, and the EU Circular Economy Action Plan. ams-OSRAM AG Page 1 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process EXECUTIVE SUMMARY In conclusion, due to the socioeconomic benefits of the use of ams OSRAM products and downstream applications, the current lack of alternatives for most uses of PFAS in the semiconductor production processes and final products, and the low PFAS volumes used compared to other dispersive uses, and that emissions are being controlled, managed and reduced at the production processes, ams OSRAM would like to request the following derogation: "the semiconductor manufacturing process, all required upstream processes for components and production equipment and all downstream applications, for a 20 years period after EiF with appropriate review periods to review the developments and availability of new alternatives" ams-OSRAM AG Page 2 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process BACKGROUND INFORMATION 2. BACKGROUND INFORMATION 2.1 Regulatory background on PFAS The EU has been actively working to restrict the manufacture, use and placing on the market of PFAS in the EU. Entry 68 of Annex XVII of REACH (Restriction List) restricts the manufacture, use and placing on the market of C9-C14 perfluorocarboxylic acids (PFCAs), including their salts and any combinations thereof above a certain concentration in the mixture or article. The restriction includes derogations until July 2025 for uses in semi-conductor manufacturing, photographic coatings in films, invasive and implantable medical devices and in some fire-fighting foams1. This restriction originally also included perfluorooctanoic acid (PFOA), its salts and PFOArelated substances, but the scope was narrowed down to C9-C14 acids after the inclusion of PFOA in Annex I (prohibition) of the POP Regulation in 2020. Perfluorohexane-1-sulphonic acid (PFHxS), its salts and related substances was also included in Annex IV (waste management provisions) of the POP Regulation in 2022. Undecafluorohexanoic acid (PFHxA), its salts and related substances are in the process of being restricted in the EU. The proposed restriction includes a number of timed derogations, such as for chrome-plating, in some fire-fighting foam applications, in protective garments, medical devices and in filtration and separation media. ECHA's committees have issued their final opinions and the restriction proposal will be decided by the European Commission2. PFAS in fire-fighting foams (FFF) is also in the process of finalisation. On 22 March 2023, ECHA officially published the universal PFAS restriction proposal, and initiated a six-month public consultation. The restriction proposal includes a number of proposed time-limited derogations and derogations for reconsideration for some of the assessed (sub-)uses. The decisions on derogations were made on the basis of the availability of alternatives and the feasibility of substitution, along the potential for environmental emissions for each (sub-)use. The public consultation requests stakeholders to provide any relevant information to the uses, alternatives, waste management and environmental fate of PFAS in the EEA. The requested information is on: 1. Sectors and (sub-)uses. 2. Emissions in the end-of-life phase (in the EEA), including emission levels and waste treatment methods. 3. More specifically, the effectiveness of incineration with respect to the destruction of PFAS 4. Impacts on the recycling industry with respect to the concentration limits for PFAS and any incurred costs. 5. Tonnage and emissions for the proposed derogations. 6. Alternatives and socioeconomic impacts for uses not assessed in the restriction proposal, including volumes, functionalities of PFAS, suitability and availability of alternatives, costs, time and difficulties for substitution, and any socioeconomic impacts in case substitution is not feasible. 7. Any information on alternatives and socioeconomic impacts to justify the derogations that are marked for reconsideration by the dossier submitters. 1 See https://echa.europa.eu/documents/10162/f9e7b269-87cd-fc26-1a8e-b8c8b6e40c08 2 See https://echa.europa.eu/registry-of-restriction-intentions/-/dislist/details/0b0236e18323a25d ams-OSRAM AG Page 3 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process USES OF PFAS IN THE SEMICONDUCTOR MANUFACTURING PROCESS - DESCRIPTION OF MOST IMPORTANT USES 8. Any additional information on alternatives and socioeconomic impacts for identified uses that have no proposed derogations in the restriction proposal. 9. The degradation potential of specific PFAS sub-groups. 2.2 Information on the stakeholder ams OSRAM is headquartered in Germany and Austria and has more than 21,000 employees worldwide. ams-OSRAM continuously advances industry-leading technologies in sensing, illumination and visualisation. In Europe, ams-OSRAM produces semiconductors in two plants located in Premstaetten (Austria) and Regensburg (Germany). ams OSRAM's product portfolio comprises light emitters, optical components and modules, light sensors and associated integrated circuits (IC), algorithms and software as well as platforms for optical applications. One priority of ams OSRAM is the development of green technological products and solutions. ams OSRAM products increase security and energy efficiency in automotive mobility, industry, medical applications as well as mobile applications, consumer products and intelligent lighting. 2.3 Aim of the report ams OSRAM submits this report to the public consultation on the proposal for a restriction of PFAS, which was initiated by ECHA and extends until 25 September 2023. As part of their response, ams OSRAM wants to present relevant data on the uses and applications of PFAS in the semiconductor manufacturing process. The information provided will demonstrate the necessity of the use of PFAS in this process, the availability or lack of alternatives for substitution, and the importance of the continued use in the EEA to support the current proposed derogation as presented in the restriction proposal text: derogation 5 .ee [the semiconductor manufacturing process, all required upstream processes for components and production equipment and all downstream applications, for a 20 years period after EiF with appropriate review periods to review the developments and availability of new alternatives." 3. USES OF PFAS IN THE SEMICONDUCTOR MANUFACTURING PROCESS - DESCRIPTION OF MOST IMPORTANT USES 3.1 Use in the Photolithography, wet etching of silicon dioxide coatings and plasma etching. The production of circuits on semiconductor wafers are done using several sequential steps where layers are selectively added and carved from the starting material and subsequent added layers. Photolithography is the process to pattern parts on the wafer substrate. During the photolithography a film of photoresist (light sensitive polymer) is applied to the substrate material. The photoresist is altered on exposure to light making it easier or harder to remove. In this manner, selected parts of the substrate material or subsequent added layers are removed (etched). In this processes PFAS form part of the photoresist itself, act as a photoacid generator or act as photosensitizers. PFAS are also used as antireflective coatings between the different layers, to improve the photoetching process. For a review on the different PFAS used in the photolithography process refer to Glge et al. 3 (2020), supplementary information, and references therein. 3 Juliane Gluge, Martin Scheringer, Ian T. Cousins, Jamie C. DeWitt, Gretta Goldenman, Dorte Herzke, Rainer Lohmann, Carla A. Ng, Xenia Trieri and Zhanyun Wangj. (2020). An overview of the uses of per- and polyfluoroalkyl substances (PFAS). Environ Sci Process Impacts1;22(12):2345-2373. doi: 10.1039/d0em00291g. ams-OSRAM AG Page 4 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process USES OF PFAS IN THE SEMICONDUCTOR MANUFACTURING PROCESS - DESCRIPTION OF MOST IMPORTANT USES PFAS are also used as surfactants in the wet etching of silicon dioxide coatings. The PFAS not only facilitate wetting of the area to help produce sharp detail, but also reduce the reflection of the etching solution, achieving accuracy and precision that would not be possible without their use. Additionally, another process known as plasma etching is also used in the manufacture of semiconductors. In this case, PFAS in oxygen plasma generate a variety of reactive species that breakdown chemical layers and deposits, selectively removing them. PFAS are also widely used in the intermediate cleaning steps during the semiconductor production processes. These cleaning steps are either oxidative and etching steps (or a combination of the two). Several PFAS substances are used in these cleaning steps. 3.2 Use in Cleaning of the plasma deposition chambers. PFAS are used in between semiconductors manufacturing steps to clean chemical vapour deposition (CVD) chambers with aim of removing dielectric film build up. 3.3 Use in Working fluid for vacuum pumps. During all the production processes, PFAS containing fluids are used as working fluid in high performance vacuum pumps. 3.4 Use in Lubricants Solid and liquid lubricants are used to reduce friction and wear between surfaces and as a sealant. The lubricants used in the manufacture of semiconductors are high-performance materials that need to be stable at both changing temperatures and changing pressure. Among other critical properties, PFAS containing lubricants require to be inert and resistant to harsh chemicals. This use should be covered by the proposed derogation 5. s. "lubricants where the use takes place under harsh conditions, or the use is needed for safe functioning and safety of equipment until 13.5 years after EIF". 3.5 Use in Manufacturing equipment. Fluoropolymer-based coating of equipment used in the manufacturing processes. Perfluoroelastomers are used where the processing equipment is in direct contact with the chemicals used in the photolithography process as well as in contact with wet aggressive chemical environment or dry plasma etching gases. Laboratory equipment such as small parts and devices, e.g., washers, gaskets, coatings of other materials inside machines and semiconductor manufacturing equipment, tubing and various very small parts that require to be resistant to harsh conditions as high temperature, abrasion, corrosive chemicals and mechanical stress. 3.6 Use in Wafer containers. During the production process, semiconductors are contained and transported to the different processing equipment on fluoropolymer made containers, because of their inertness and resistance to chemically and physically aggressive environments. Without these containers the transfer and processing of the semiconductor wafers would not be possible. 3.7 Use in Heat transfer fluids. Several semiconductor manufacturing processes entail physical and chemical processes that require precisely controlled temperatures, and thus are highly reliant on fluorinated heat transfer fluids (F-HTFs) and fluorinated refrigerants. In both cooling and heating applications, F-HTFs help ensure the ability to provide the precise temperature control required in specific manufacturing operations. Additionally, cooling machines with PFAS refrigerants provide cooling water for the semiconductor production equipment. ams-OSRAM AG Page 5 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process VOLUMES OF PFAS IN SEMICONDUCTOR MANUFACTURING PROCESSES 3.8 Use in Refrigeration of Clean Rooms and production equipment. Refrigerant gases in chillers and AHU/HVAC-units are needed to maintain the clean-room temperature and humidity under all weather conditions. In many of these equipment, the refrigerant gases used are PFAS. 3.9 Use of PFAS in various components used in the production process. Polymeric PFAS are used in all semiconductor manufacturing processes. Part of those is included in the manufacturing equipment (see 3.5). Pipes, valves, tanks and containers, wafer carriers and chucks (as mentioned above in 3.6), membranes of filters (for gases and liquids), bearings, fittings, O-rings, seals, housing, among other components, require to be resistant to the harsh chemical conditions during the manufacturing process. Additionally, these components require to be heat stable, nonflammable, and should not release any contaminating substance by volatilization. 3.10 Use of PFAS in the finished semiconductors Although there are no residual PFAS in the semiconductors, as any kind of impurity on the semiconductors would prevent the correct working of it and it would render the semiconductor unusable, there are PFAS containing materials that are part of the packaging of semiconductors and components, such as part of connecting cables. This depends on the final use of the semiconductor and are added later. Therefore, these are not strictly considered in the semiconductor manufacturing process. A detailed overview on all the different assembly, packaging and substrates that are generally used with the semiconductors that might contain PFAS, including possible alternatives being developed has been thoroughly described by the SIA4. Particularly for some ams OSRAM products, PFAS are also part of the coating of lenses, due to their low refractive index5, and resistance to the high temperatures that develop during its use. Additionally in some special cases fluoropolymers remain as a protection layer after the production process. 4. VOLUMES OF PFAS IN SEMICONDUCTOR MANUFACTURING PROCESSES In general, the volumes of PFAS used in the semiconductor manufacturing are relatively low. As a general trend production of the finished products that use ams-OSRAM semiconductors are increasing, therefore there is increasing production demand, but in the semiconductor business sometimes demand is highly variable. Total PFAS uses are difficult to estimate because suppliers are not obliged to disclose PFAS content in their products. The estimated amount of PFAS used in the production processes of semiconductors by ams-OSRAM is only around 10 t/a. See details in Table 1, and some clarifications sorted by physical stated of the PFAS in the following text. 4 See. SIA Whitepaper: PFAS-Containing Materials Used in Semiconductor Manufacturing Assembly Test Packaging and Substrate Processes Semiconductor PFAS Consortium Assembly, Test, Packaging and Substrates Working Group, June 2, 2023 5 https://onlinelibrary.wiley.com/doi/full/10.1002/ajim.23362Historical and current usage of per- and polyfluoroalkyl substances (PFAS): A literature review - Gaines - 2023 - American Journal of Industrial Medicine - Wiley Online Library ams-OSRAM AG Page 6 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process VOLUMES OF PFAS IN SEMICONDUCTOR MANUFACTURING PROCESSES Table 1 Volumes of PFAS used in semiconductors manufacturing at ams OSRAM Use PFAS product Estimated volume used 3.1 Photolithographic estimated content of PFAS (> 5-6 t/a, thereof 1-1.5 t are process 0.1% wt) in the solutions used in PFAS the photolithographic process 3.1 + 3.2 Plasma etching and Etching gases 8.5 t/a (input; actual cleaning of plasma etching emissions estimated: < 5%) chambers 3.3 Working fluid in vacuum pumps 3.4 Lubricants 3.5 Parts in the production* machinery 3.6 Error! Reference source not f ound.Wafer containers 3.7 Heat transfer fluids 3.8 Use in Refrigeration of Clean Rooms and production equipment 3.9 Use of PFAS in various components used in the production process. 3.10 Part of some finished semiconductors TOTAL PFAS chemicals Working fluid in vacuum pumps. Exact composition has not been provided by external suppliers. Lubricant in manufacturing equipment. Exact composition has not been provided by external suppliers. washers, gaskets, O-rings, tubing and other small parts Polymeric PFAS Perfluoropolyether (Hexafluoropropene + Tetrafluoroethylene) Refrigerant gases contained in the refrigeration equipment Pipes, valves, tanks and containers, membranes of filters (for gases and liquids), bearings, fittings, O-rings, seals Various PFAS containing materials that are part of the packaging of semiconductors and components 400 l (annual amount replaced by external service unknown) Unknown. Information has been requested to external provider. Unknown. 0.1 t/a 5 l/year 0.1t/a Unknown, total estimated 23 t (estimated 0.1 t/a annual replacement) Unknown, information check on materials is being conducted with suppliers Approx. 10 t/a Solid PFAS articles No reliable data is available as many PFAS-containing articles are not inventoried separately and/or are only a part of a bigger manufacturing instrument. Wafer carriers and other smaller articles are disposed of in quantities of approx. 50 kg/year per production facility, so the estimated annual tonnage for this use is approx. 100 kg/year. Liquid PFAS chemicals or PFAS containing mixtures Pump-oil for vacuum pumps: total estimated 200 l/a per factory (e.g. almost 700 individual vacuum pumps are used in the Regensburg factory). The annual amount replaced by external servicing technicians is unknown. Photolithography process: 5-6 t/a (2-3 t/a per production facility), PFAS content < 0,1 % (although this may be more but is unknow as information is confidential and not provided by the suppliers). If it is considered that about 0.1% of the solutions used in the photolithographic process are PFAS, an estimated amount of 1 to 1,5 t/a are used in the EU production facilities. ams-OSRAM AG Page 7 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process EMISSIONS PFAS gases Refrigerant gases: 100 kg/year. This is an estimation as no exact numbers are known. The refrigerant gases are contained in the equipment, the exact information on how much refrigerant gases need to be replenished during the service by external providers has been requested but is not available to ams OSRAM at the moment. Plasma etching and cleaning of plasma etching chambers: 8.5 t/a. Slightly increasing trend dependant on business (total used in both manufacturing facilities in the EU). 5. EMISSIONS 5.1 Production process Solid articles are disposed of as industrial waste (small items) or as plastic waste for recycling if larger items like pipework, tanks or valves need to be disposed of in case of factory refurbishment. In Germany and Austria non-recyclable waste is incinerated in designated official waste incineration plants that are subject to local regulations (stemming from EU legislation). PFAS materials are therefore destroyed (thermal decomposition) and removed from the effluent gas by various cleaning technologies. Ash and slag are disposed of in special dedicated (often underground) disposal sites according to national and EU law. Pump-oils are changed regularly; the pumps are refurbished and refilled at the manufacturers facilities in the UK then they are returned to the site. Final disposal of the used pump oil has not been communicated by the pump manufacturer. Other liquid PFAS waste (such as waste from the solutions used in the photolithographic production process and heat transfer fluids) are collected and shipped to special waste treatment facilities off-site. Hazardous chemical waste is usually incinerated using higher temperatures than household waste incineration. For PTFE, incineration using best available technologies has been shown to eliminate PFAS from the waste treatment6. Air emissions from abatement systems: After the plasma etching process the excess gases and decomposition products are incinerated in special gas fired abatement systems connected to the production equipment, subsequently the effluent gas passes through a scrubber to remove the combustion products with an effectivity of approx. 95-98%. The scrubber liquid (alkaline water) is then treated in the on-site neutralization plant. The purified water is discharged to the public sewer. The filters used on the process are disposed of with other solid articles as industrial waste as described above. ams OSRAM is currently measuring PFAS in the wastewater, to confirm that no PFAS are being released to the municipal wastewater, and to identify and correct any emission. Preliminary measurements performed on 2022 did not detect significant amounts of 8 PFAS analysed in wastewater effluents. Due to the high volume of such requests to analytical laboratories, the results of the more detailed measurements have not been yet received by ams OSRAM at the moment this document was prepared and submitted. 6 Waste incineration of Polytetrafluoroethylene (PTFE) to evaluate potential formation of per- and Poly-Fluorinated Alkyl Substances (PFAS) in flue gas, Aleksandrov et al., 2019, Chemosphere226, 898-906. https://doi.org/10.1016/j.chemosphere.2019.03.191 ams-OSRAM AG Page 8 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process ANALYSIS OF ALTERNATIVES Air emissions from refrigeration systems and chillers are minimal and regulated in the respective EU7 and national laws for the operation of these machines. 5.2 End-of-life of finished products There are no PFAS in the semiconductors produced. However, the final products where these semiconductors are integrated might contain PFAS. For example, some parts such as connection wires between the semiconductor and other parts of the finished products are sheeted with PFAS containing materials. Some glues used in the attachment of the semiconductors to other parts also contain PFAS. ams OSRAM is currently collecting information from its suppliers about components that might contain PFAS, and possible replacements. The end of life of the semiconductor-containing products, will depend on the downstream product. The downstream products that are electronic waste are disposed of or recycled, depending on where the product was used. In the EU disposal has to be done following the directive of Waste from Electrical and Electronic Equipment (WEEE). In the USA disposal has to follow the regulation issued by United States Environmental Protection Agency EPA. Additionally, in the case the final products are incorporated in vehicles, according to the existing guidelines and regulations 8 , they should be dismantled and all parts properly reused, recycled and disposed of 6. ANALYSIS OF ALTERNATIVES Currently, no alternatives have been identified for most of the PFAS uses in semiconductor production. In the semiconductor manufacturing process, hazardous, toxic, flammable, corrosive and highly reactive chemicals are used usually at high temperatures and in high vacuum conditions. That is why in most cases and due to their chemical properties only PFAS can be used due to their chemical inertness, mechanical resistance, thermal resistance and because they do not release contaminant substances by evaporation. The exact critical properties of the PFAS used vary depending on the specific use. Additionally, in most uses all of the mentioned properties are important, and in specific uses materials lacking some of these properties, could lead to safety issues (e.g., explosion risk), contamination of the semiconductors that severely interfere with their functioning or directly render them useless. Contamination may also lower the performance of the production process, which results in higher use of materials, increased energy and water consumption, to mention some possible consequences of the replacement of PFAS in the affected process. The Semiconductor Industry Association (SIA) has carried out an exhaustive investigation in order to find alternatives to PFAS substances used in the semiconductor manufacturing process. This assessment is described in detail in a series of white papers9 where the technical challenges for replacing the PFAS in the semiconductor production processes are outlined, therefore they will not be reviewed here. In most cases, even if an alternative was available and could be implemented, the substitution would require between 4 to 10 years, which depends on what exactly in the process must be changed. 7 Regulation (EU) No 517/2014 of the European Parliament and of the Council of 16 April 2014 on fluorinated greenhouse gases and repealing Regulation (EC) No 842/2006 8 End-of-life vehicles. Summary of Directive 200/53/EC. With links to legislations texts 9 SIA's white papers are published here -Semiconductor PFAS Consortium - Semiconductor Industry Association (semiconductors.org) ams-OSRAM AG Page 9 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process SOCIOECONOMIC IMPACT ASSESSMENT In cases where no alternatives are currently available, the time required to develop an alternative technology in semiconductor manufacturing processes would require more than 25 years, which includes R&D efforts, qualification and the final implementation of the new fabrication devices or adapted process of the existing ones.10 ams OSRAM is constantly evaluating alternatives, and wherever possible implementing changes where non PFAS alternatives have been identified. For example, for the use of methoxy-nonafluorobutane (C4F9OCH3) for the cleaning of the plasma etching chamber a non PFAS alternative was identified (NF3), and replacement is currently being made in the production facilities. 7. SOCIOECONOMIC IMPACT ASSESSMENT 7.1 Market overview and downstream products ams OSRAM is a leading global player in core lighting markets such as the LED market (second main player) (Trendforce 2022) and the Light Sensors (second main player) (OMDIA 2021) and the automotive lamps/bulbs aftermarket. ams OSRAM generated a revenue of 1.455 billion in EMEA (Europe, Middle East and Africa), in 202211. ams OSRAM products have multiple applications in modern life and fulfil several market sectors dealing with societal sectors such as transport, energy efficiency, medical applications, industrial and defence sectors. ams OSRAM products increase security and energy efficiency in the automotive and mobility applications such as light detection and ranging (LIDAR) technology used for advance driver assistance, smart and energy efficient lighting and in-cabin sensing. Other downstream uses of ams OSRAM products include consumer products that contain, for example UV-A sensors or vital sign monitoring sensors, and energy saving screens with micro-LED technology. Industrial and medical applications include energy-saving UV-C disinfection without using chemicals or mercury lamps, horticulture LEDs and high-performance medical imaging for better quality/diagnostics with lower radiation for patients and doctor. Further examples can be found in the ams OSRAM Sustainability Report 202212. 7.2 Wider socioeconomic impact Without semiconductors and their downstream applications, many modern life activities would be impossible. The semiconductor industry has great strategic importance on the strive for digital selfsufficiency of the EU because semiconductors are part of most strategic and critical value chains, such as telecommunications, electro-mobility and energy power generation, medical equipment, highperformance computers, computer peripherals, defence and security, and the emerging artificial intelligence. Therefore semiconductor-based technologies are considered key for the implementation of EU strategic objectives such as the EU Green Deal and the EU Digital Strategy. To achieve these strategic objectives, several policy-based initiatives are currently being implemented in EU where semiconductors are an essential part: the EU Chips Act, the EU's Net-Zero Industry Act, The Digitalisation of the European Energy System, and the EU circular economy action plan. 10 See also The Impact of a Potential PFAS Restriction on the Semiconductor Sector, SIA PFAS Consortium, 2023 11 Financial Reports - Annual Reports | ams OSRAM (ams-OSRAM.com) 12 ams-OSRAM-Sustainability-Report-2022.pdf ams-OSRAM AG Page 10 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process SOCIOECONOMIC IMPACT ASSESSMENT 7.2.1 EU Chips Act The European Chips Act, adopted on 25 July 2023, aims to reinforce Europe's competitiveness and resilience in semiconductor technologies and applications and help achieve both the digital and green transition13. The World Economic Forum has estimated that the scaling of digital technologies could reduce up to 20% of carbon emissions by 2050, contributing in that way to achieve the net zero goals of the International Energy Agency in the energy, materials and mobility industries.14 In 2020-2021 there was a global shortage of semiconductors, affecting a wide range of sectors, from car manufacturing to healthcare equipment. The EU Chip Act was conceived to counteract future chips scarcities, as the shortage made evident the extreme global dependency of the semiconductor value chain on a very limited number of stakeholders in a complex geopolitical context. The semiconductor industry worldwide manufactured around 1 trillion microchips in 2020. Only 10% of that was produces in the EU. One of the aims of the European Chips Act is to double it by 2030. This Act proposes to achieve this goal by strengthening the EU semiconductor industry mobilizing more than 43 billions of public and private investments and issuing measures to prepare, anticipate and swiftly respond to any future supply chain disruptions, together with Member States and key international partners. The EU Chips Act is expected to result in additional public and private investments of more than 15 billion. Other objectives of the EU Chips Act are strengthening Europe's research and technology leadership towards smaller and faster chips, build and reinforce capacity to innovate in the design, manufacturing and packaging of advanced chips, develop an in-depth understanding of the global semiconductor supply chains; and address the skills shortage, attract new talent, and support the emergence of a skilled workforce. The continued use of PFAS substances is essential at all levels of the supply chain, from the manufacturing stage to placing in the market of semiconductor products. The continued use of PFAS, until new alternative materials and technologies are available, is essential to allow promote the desired EU semiconductor industry growth in the medium and long term. 7.2.2 EU's Net-Zero Industry Act - EU decarbonisation goals The Net-Zero Industry Act aims to help strengthen the European manufacturing capacity of net-zero technologies and overcome barriers to scaling up the manufacturing capacity in Europe15. The declared goal for the manufacturing capacity of strategic net-zero technologies is to meet at least 40% of the EU's annual deployment needs by 2030. Additionally, a target of 50 million tonnes of annual CO2 storage capacity by 2030 has been set. The Net-Zero Act goals should be achieved through creation of conditions for investments in net-zero technology manufacturing projects, set up of training programs to enhance skills, and creation of platform for information exchange between the EU, member states, and stakeholders. 13 European Chips Act (europa.eu) 14 Digital technologies can cut global emissions by 20%. Here's how | World Economic Forum (weforum.org) 15 The Net-Zero Industry Act (europa.eu) ams-OSRAM AG Page 11 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process SOCIOECONOMIC IMPACT ASSESSMENT The Net-zero technologies that are targeted by the Act are, among others: Solar photovoltaic and solar thermal technologies Onshore and offshore renewable technologies Battery/storage technologies Heat pumps and geothermal energy technologies Electrolysers and fuel cells Sustainable Biogas/Biomethane technologies Carbon Capture and Storage (CCS) technologies Grid technologies The increasing amount of energy obtained from renewables required to achieve the emission targets set by the EU in 2020 requires an energy system capable of supporting it. Today's energy system is still heavily reliant on fossil fuel. By 2050, the final energy demand is estimated to increase by 53%, with an increased share of electricity from renewable sources of over 80%16. In order to prepare the energy system for these future challenges, including increased storage of energy and distribution of the energy generated, digitalization is key to a smarter and more interactive system. This can only be made possible by semiconductors. 7.2.3 EU circular economy action plan The EU circular action plan is necessary for a cleaner and more competitive Europe17. It will reduce pressure on natural resources and its implementation will create sustainable growth and jobs. The action plan encompasses initiatives on the entire life cycle of products and aims to ensure that waste is prevented, and the resources used are kept in the EU economy for as long as possible. To have a maximum impact the plan focuses on the sectors that use the most resources and where the potential for circularity is high, including the electronics, ICT, batteries, and vehicle sectors. Emerging digital technologies such as big data, artificial intelligence (AI), blockchain, and the Internet of Things (IoT), among others are going to play and important role to steer and enable circular economy. These digital technologies combined with business model innovation provide solutions for the transformation of the circular economy18. Digitalisation enables and accentuates introduction of circular business models (CBMs). As semiconductors are at the heart of digitalization, the semiconductor industry will play an important role in enabling the digital technologies needed to support a successful circular economy in the EU and worldwide. 16 Digitalisation of the European Energy System | Shaping Europe's digital future (europa.eu) 17 Circular economy action plan (europa.eu) 18 Chetna Chauhan, Vinit Parida, Amandeep Dhir. Linking circular economy and digitalisation technologies: A systematic literature review of past achievements and future promises. Technological forecasting and Social Change. 177 Technological Forecasting & Social Change 177 (2022) 121508, https://doi.org/10.1016/j.techfore.2022.121508 ams-OSRAM AG Page 12 ams-OSRAM AG Response report to PFAS restriction proposal "Semiconductor manufacturing production process CONCLUSION AND PROPOSAL FOR PUBLIC CONSULTATION 8. CONCLUSION AND PROPOSAL FOR PUBLIC CONSULTATION ams OSRAM produces light emitters, optical components and modules, light sensors and associated integrated circuits (IC).ams OSRAM products are used in a variety of industrial applications and consumer products. The use of microLEDs produced by ams OSRAM improve energy efficiency of the downstream products while reducing emissions and use of resources. PFAS are used in several steps of the semiconductor's production processes. They constitute an irreplaceable part of the production equipment or the final products. During the semiconductor manufacturing process hazardous, toxic, flammable, corrosive and/or highly reactive chemicals are used. Many of these processes are performed at high temperatures and/or in high vacuum conditions. That is why materials that are chemically inert and have high mechanical and thermal resistance are required. In most cases only PFAS fulfil these requirements. Furthermore, the PFAS materials used in the production of semiconductors do not release any contamination (as a particle or substance) that would compromise the manufacturing process. ams OSRAM is actively replacing PFAS in any use where alternatives exist and are available, such as in the use of methoxy-nonafluorobutane (C4F9OCH3) for the cleaning of the plasma etching chamber. However, as this report is being prepared, there are no PFAS-free material or chemicals, or alternative technologies that can be used to replace PFAS in most of the manufacturing uses. Upstream developers of the equipment used for semiconductor manufacturers and suppliers of chemicals used in the existing processes are continuously researching to improve their products, and part of that should research include replacements for the currently used PFAS, but their replacement is estimated to take between 4 to 10 years of implementation where alternatives have been identified. Where further R&D is needed to develop new alternative substances or entirely new processes, the estimated required time is more than 25 years. The emissions of PFAS during the production processes are being actively managed and minimized. ams OSRAM products and downstream applications contribute to several strategies of the EU, such as the EU Green Deal and the EU Digital Strategy. In conclusion, due to the socioeconomic benefits of the use of ams OSRAM products and downstream applications, the current lack of alternatives for most uses of PFAS in the semiconductor production processes and final products, and the low PFAS volumes used compared to other dispersive uses, and that emissions are being controlled, managed, and reduced at the production processes, ams OSRAM would like to request the following derogation: "the semiconductor manufacturing process, all required upstream processes for components and production equipment and all downstream applications, for a 20 years period after EiF with appropriate review periods to review the developments and availability of new alternatives" ams-OSRAM AG Page 13