SEMI Seeks Improved Rules for China Trade

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SEMI Seeks Improved Rules for China Trade

Does your company, like many in the global semiconductor equipment and materials industry, face licensing requirements to sell products to Chinese customers? These rules apply to a wide range of tools—such as etch, CVD, ion implantation and lithography equipment, as well as a number of materials. SEMI would like to hear your views on how these rules can be improved.

Wassenaar Arrangement Needs Industry Input

Almost all geographies with a major equipment and materials base are members of the Wassenaar Arrangement, a multilateral group, which governs export controls for items that can be used for either civilian or a military use. Many of these licensing requirements apply for trade with China.

Wassenaar is preparing for its 2008 assessment of their control list and is looking for industry input. SEMI has had some previous success in changing Wassenaar controls such as the decontrol of test equipment. We have been asked to submit recommendations on behalf of the industry, so please let us know what changes you would like to see.

SEMI Urging Streamlining of U.S. Commerce Control List

In a similar effort, the U.S. Commerce Department is reviewing the Commerce Control List that outlines which items require licenses for export from the United States. This review is the first step in an overall analysis of current U.S. controls and how they should be updated to reflect a changing global environment. SEMI has been asked to provide comments on the overall structure of the list, changes to specific descriptions, and coordination of controls with the Wassenaar Arrangement.

The Commerce Control List affects China trade, includes out-of-date technologies and contains licensing requirements for both U.S. and non-U.S. companies. Overall, the list generally includes the Wassenaar controls as well as unilateral U.S. controls. All relevant licensing requirements for our industry are in effect for exports to China. The control list has not been comprehensively reviewed in about 15 years and has only seen incremental change during this time. The requirements apply not only to U.S. companies, but also to overseas companies exporting from U.S. facilities.

SEMI is preparing comments and will urge the government to streamline the list by decontrolling most items while keeping focused controls on the items that matter the most. We will also prepare more specific comments that reflect our members’ needs. We urge you to let us know what would be the most useful for your company. Comments are due November 1 and SEMI will follow up with meetings with key government officials to discuss the industry’s views.

For more information, please contact Maggie Hershey at