SEMI Letter to Suppliers Regarding REACH (June 2009)


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SEMI – Semiconductor Equipment and Materials International

Date: June 30, 2009

To: Industry Colleague and Supplier to the Semiconductor Industry

From: SEMI Global Headquarters (3081 Zanker Road, San Jose, CA 95134 – USA)

Re: The European REACH Regulation

Dear Industry Colleague and Supplier to the Semiconductor Industry,

As you are no doubt aware, the regulatory nature of the world is very challenging. The impacts of chemical control laws enacted in one region of the world extend across national boundaries due to the interconnected nature of supply chains.

As a supplier to the semiconductor industry, compliance with global regulatory requirements is a necessity for maintaining your business, regardless of your immediate point of sale.

The European regulation EC/1907/2006, also known as “REACH” is one of the global regulations that is currently challenging the semiconductor industry supply chain. More information on REACH is located here:

http://guidance.echa.europa.eu

Under REACH, equipment suppliers (i.e. your potential customers) are responsible for having a detailed understanding of the substances incorporated into their products. This includes both the hardware and the containerized chemicals shipped along with their products to facilitate installation, operation, service, and maintenance. [The term “containerized chemicals”, used here is meant to represent the “substances” or “preparations” with the REACH regulation.] In many cases, this information has to be communicated to their end customers and European authorities.

To this end, your customers, the equipment suppliers, would like to ensure that you have knowledge of the following areas:

  • You need to know whether your products contain any materials listed in REACH’s Candidate List of Substances of Very High Concern (SVHC), Annex XVII (Restrictions on the Manufacture, Placing on the Market and Use of Certain Dangerous Substances, Preparations and Articles), or Annex XIV (List of Substances Subject to Authorization)
  • The equipment supplier expects that you assess not only the product itself, but all packaging material that is provided with your product
  • Under REACH, the manufacturer / importer has the responsibility for providing EU compliant MSDSs and labels for containerized chemicals. Equipment suppliers will typically expect that you provide these as an input to their response under these obligations.
  • It is recommended that chemicals to be resold into the EU be addressed in commercial agreements between the chemical supplier and the party which will resell the product.
  • In order to be successful, these requests may need to travel up the supply chain to your suppliers and their suppliers.

We are requesting that all suppliers to SEMI member companies:

  • Report information to your customers (i.e. equipment manufacturers) concerning the materials, on the above referenced lists, incorporated into your products and their packaging
  • If you sell containerized chemicals, provide a safety data sheet conforming to the EU regulations or be able to provide the information to your customers (i.e. equipment manufacturers) that have an obligation to develop one
  • Assign a specific person (or contact method) so that your customers can communicate with you regarding REACH and other global chemical regulatory issues
  • Proactively work with your customers to develop a means of managing the challenges of this regulation as efficiently as possible

We would like to assist you in understanding all of these points in greater details and fill any knowledge gaps you may have. To assist us, please complete this survey:

http://www.semi.org/en/ctr_028764

In response to the needs identified in the survey, we will develop training materials to help you.

Should you have any questions, please feel free to contact Sanjay Baliga, SEMI Senior EHS Manager, by email at sbaliga@semi.org or by phone at 1.408.943.6957. We look forward to assisting you.

Sincerely,

Stanley T. Myers

President and CEO

SEMI – Semiconductor Equipment and Materials International

A PDF copy of this letter is located here.