III-V Compounds under the Microscope of European EHS Rules — What’s the Impact on the Industry?
The semiconductor industry is a complex business with multiple challenges on many fronts, including public policy. EU rules and regulations can be difficult to understand and implement, and sometimes they place an additional burden that slows down our fast-moving industry. To help keep our industry competitive on a global scale, SEMI Europe is committed to public policy — maintaining a Brussels office, which advocates for the SEMI members early in the decision-making process, so that final decisions reflect a balanced approach that keeps the needs of our industry protected.
Ourania (Rania) Georgoutsakou is our new director of Public Policy in Brussels. Rania has over ten years’ experience in public policy and lobbying in Europe. She is responsible for advocating for the interests of SEMI members with both the EU and national governments. She evaluates and analyzes EU regulations which affect the semiconductor, photovoltaic and related industries. In addition, she manages the policy-related SEMI executive events (Brussels Forum, Executive Summit) and is involved with the European Advisory Board.
By Rania Georgoutsakou, director, Public Policy, SEMI Europe
The potential impact of the EU’s environmental, health and safety (EHS) regulations on the semiconductor industry becomes reality, as the first III-V compounds begin a journey toward classification as hazardous substances. The semiconductor industry needs to demonstrate three things: III-V substances are essential and currently irreplaceable, the semiconductor industry is aware of the risks inherent to using these substances, and these risks are managed — based on strict standards that are reviewed and improved regularly
III-V Compounds in the European EHS Process
European EHS rules are probably most known for their complexity. Many regulations exist, and a variety of substances are under always under review (with an array of obligations forced on manufacturers). Keeping up with all of this is literally a full-time job for many. So here’s a quick look at where things stand for III-V compounds in Europe.
Two III-V compounds, Gallium Arsenide (GaAs) and Indium Phosphide (InP), are currently being evaluated under the European rules on classification, labeling and packaging (CLP). They are being classified as carcinogenic, mutagenic or reproduction toxic (CMR). This classification makes them eligible candidates for the list of Substances of Very High Concern (SVHC), which in turn implies they may be subjected to a restriction or authorization procedure, and possibly even a complete ban, under REACH (European Regulation on Registration, Evaluation, Authorization and restriction of CHemicals).
To make a long story short: these compounds have started going through a process that can lead to their restricted use and a possible total ban in the medium-term.
The Basis of Key Enabling Technologies — III-V Compounds
Key Enabling Technologies (KETs) are now one of six priority action areas for Europe’s industrial policy and they also have a prominent position in Europe’s research and innovation strategy. So Europe has clearly acknowledged the value of our technologies and is developing policies to promote further innovation and growth in the sector.
The semiconductor industry knows that III-V compounds are key ingredients for the semiconductor manufacturing process that allow for smaller, faster and more efficient products and applications. We now need to transmit this message to the people in national ministries and EU institutions and start educating them on the measures our industry has already implemented, and continues to improve, to ensure the safety of workers, consumers and the environment.
These are still the early days, as the compounds in question are still at the classification stage and their future route through the EHS process remains uncertain and depends on a number of things. But now is the time to start explaining how these compounds are used in the semiconductor industry, why they are important, and what risk management measures the industry has already taken.
Dr. Nelly Kernevez, Partnership Director for SOITEC, has joined SEMI in raising awareness among European and national decision-makers about the use of III.V compounds in the semiconductor industry. She addressed a group of representatives of national ministries for industrial policy, including the REACH sub-group of the Enterprise Policy Group, in Brussels on 30 November 2012 and explained the strategic importance of III.V compounds and the end-products they are found in. SEMI members are concerned that restricting the use of these compounds under EU EHS rules will have an adverse effect — not only on the European semiconductor industry — but on Europe’s overall growth strategy.
Europe Competitiveness: Importance of III-V Compounds
On the one hand, III-V compounds are the key ingredients for Europe’s KETs, i.e., the technologies that will allow Europe to tackle societal challenges such as climate change, energy efficiency and an ageing population and that will also contribute to economic growth and competitiveness. III-V compounds have specific properties that are not replaceable today — eliminating them would mean sacrificing speed, efficiency and innovation potential.
On the other hand, the semiconductor industry is very much aware of the risks associated with certain substances. This is why for years we have been developing EHS standards in associations such as SEMI, where companies put aside any concerns about working with competitors and jointly develop risk management standards and benchmark with each other. Consumers are not exposed to these substances, as they are encapsulated, inert and bulk. We work together to implement European and other regulations on waste and safely dispose of any harmful elements. The risks are known and managed responsibly.
This does not need to become a choice between promoting growth on the one hand, and providing a high level of safety on the other. We can demonstrate that the semiconductor industry is already managing the risks — and that there is no need to restrict or ban the use of these compounds.
SEMI will continue to monitor developments in this area and work with members to raise awareness about the use of these compounds and the risk management standards in place. For further information, please contact Ms. Ourania Georgoutsakou, director, Public Policy Europe, at email@example.com.
In addition to Advocacy, SEMI is involved in strategic positioning, roadmaps and positioning papers, issue forums, exhibitions, and executive events. For more information on SEMI Europe, please visit www.semi.org/eu.
December 6, 2012