SEMI & EU REACH- impact on semiconductor manufacturing equipment

Rania GeorgoutsakouDirector Public Policy for Europe, SEMI

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Outline

• Introduction to semiconductor manufacturing equipment– Product complexity (number of potential articles)– Nature of supply chain – Sector’s control over the supply chain

• Substances in articles – SEMI understanding and questions about ECJ ruling:

– How to enforce definition of article? – Questions that have been raised– Proposals that have been floated

• Restrictions on substances in articles – PFOA– How SEMI uses PFOA in articles– SEMI concerns about proposed restriction

• Sustainable industry engagement in regulatory initiatives

About semiconductor manufacturing

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• manufacturing @ the nanometer scale -a human hair is 100K times wider than a 7nm transistor• controlled cleanroom environment • 2nd most R&D intensive industry (2015 EU Innovation Scoreboard) • EU Key Enabling Technology (EU, 2013)

Exponential technological advances

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The Electronics Supply Chain

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Semiconductor manufacturing equipment @ a glance

• High mix• Low volume• Highly customized • High Value • Long service life – sold onto many users • Subject to EU regulations (e.g. Machinery Directive, REACH)• Large scale stationary industrial tools within large scale fixed

installations• Subject to industry-wide standards• Operate under strict conditions (cleanroom environment)

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Clean room environment

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Semiconductor Manufacturing Equipment – HIGH MIX

• 10 000s – 100 000s of direct components in one product.

• Many more indirect components/articles.

• Countless ‘homogeneous layers’

Industry standards

• Drafted, voted and reviewed by industry • Cooperation across the supply chain• Regularly reviewed to reflect new technological and regulatory developments

SEMI EHS Guidelines by Topic Equipment• S2 – Semiconductor manufacturing

equipment• S26 – Flat Panel Display manufacturing

systemsEquipment related• S1 – Safety labels• S3 – Process liquid heating systems• S6 – Exhaust ventilation• S13 – Manuals• S14 – Fire risk assessment and mitigation• S17 – Unmanned transport vehicles• S22 – Electrical safety design• S28 – Robots and load ports safetyEnvironment• S12 – Equipment decontamination• S16 – Reduction of environmental impact at

end of life• S23 – Energy, utilities, and materials

conservation• S29 – Fluorinated greenhouse gas emission

Chemicals, Gases, & Distribution• S4 – Chemical cylinder separation• S5 – Flow limiting devices• S18 – Silane flammable silicon compounds• S25 – Hydrogen peroxide storage &

handlingPersonnel• S8 – Ergonomics• S19 – Installation, maintenance, and

service personnel training• S21 – Worker protection• S24 – Multi-employer work areas

Other• S7 – Evaluator qualifications• S10 – Risk assessment/evaluation• S27 – Evaluation reports

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Semiconductor manufacturing is global

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Examples of SEMI members across the supply chain

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The nature of the supply chain

Substances in articles

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What is an article?

Insulated electric cable: • PVC tube is produced separately and pulled over wire-> cable is composed of 2 articles• PVC is mixture poured over wire -> cable is 1 article

Question: is there a test to show how the cable was manufactured?

More questions:• Sheet composed of carbon fibers fixed together by a resin mixture ->

is each carbon fiber is an article?• Example of what is not an article? (i.e. shape etc. resulting from

manufacturing process is not more important than chemical properties)

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Applying ECJ ruling: How Many Articles in this Tea Kettle?

A corrosion resistant paint is needed between a bracket, and the frame to which the bracket attaches with screws. 1. The paint is 19% w/w of a candidate list substance (CLS) – 1 gram of paint is

needed in the assembly which dries to contain 0.2 grams of the CLS. Some non-CLS substances are lost from the paint due to evaporation.

2. The bracket weighs 50 grams. 3. The frame weighs 1,500 grams.4. The 2 screws weight 5 grams each (= 10 grams)

Case A - The necessary amount of paint is applied to the bracket and left to dry. The resulting article is 0.2/50.2 (or 0.4% w/w) CLS. When the painted bracket is then assembled to the frame, it is a complex product containing an article exceeding the CLS threshold.

Case B - The necessary amount of paint is applied to the frame and left to dry. The resulting article is 0.2/1,500.2 (or 0.013 % w/w) CLS. When the unpainted bracket is assembled to the painted frame, it is a complex product without any article exceeding the CLS threshold.

The order of manufacturing is important

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Issues raised by ECJ ruling

• Common definition of what is an article• Common understanding of number of articles in a complex product

>> must rely on information provided through the supply chain• Communication: supply chains are global - EU REACH is regional• Complying with information requirements while addressing IP/CBI

issues• Common understanding of most appropriate format for

communicating information• Compliance for used equipment

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Various stakeholders’ reactions to ECJ ruling • Enforcement moratorium• REACH impact on competitiveness• Supply chain due diligence• ECHA-hosted website on prioritized components• ECHA-hosted component database • Proportionality • Cut-off limits• Peanut principle• Standardised information communication format• Information re end-of-life/waste stage and overlap with other EU

legislation• Impact on restrictions (Annex XVII) to ‘articles and any part thereof’?

Restrictions on substances in articles - PFOA

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Use of PFOA in articles in semiconductor manufacturing equipmentMay be used in components/sub-components: • Chemical containers• Tubing • Gaskets• Ductwork • Filtration systems• Insulated conductors• Small mechanical assemblies• Various coatings

>>> Supply chain communication still ongoing to identify potential use and presence

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Development and validation process

V-Model of Product Development, Verification, and Validation

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SEMI concerns over PFOA restriction in articles

• Testing methods not available for all uses at time of restriction proposal

• Reliance on supply chain communication • SEMI request for 10-year derogation

– Got 5 years– possibility for review?

• Articles or any parts thereof – complete ban but what about degradation telomers?

• Potential of industry PFOA-free certification systems

Sustainable management of regulatory initiatives

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Global regulatory landscape

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Overview of regulatory initiatives impacting SEMI members - 2015• REACH – PFOA, its salts and PFOA-related substances • POP Convention – EU proposal to restrict PFOA, its salts & PFOA-

related compounds• RMOA by BAuA for PFHxA

• Basel Convention Technical Guidelines• EU F-Gas and SEMI FAQ for compliance• Conflict Minerals • Substance evaluation methodology under RoHS • On hold: NMP & RCF

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Thank you!

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Rania Georgoutsakougourania@semi.org+32 2 609 5334