PFAS

The number of regulatory proposals, including restrictions on substances such as per- and polyfluoroalkyl substances (PFAS), that could hinder the semiconductor industry’s ability to continue manufacturing is increasing. The SEMI Environmental, Health Safety (EHS) Working Groups, composed of industry technologists from across the global supply chain, meet on a regular basis to share intelligence and develop strategies to earn exemptions and/or extensions from regulators to enable the industry to continue manufacturing the chips critical to our modern way of life.In addition to an EHS session each year at SEMICON West, SEMI also hosts a full-day EHS Summit annually. This year’s event will be held on Thursday, May 26 at SEMI Headquarters in Silicon Valley. Experts from AGC, Beveridge Diamond, Intel, Tokyo Electron, SEMI Public Policy Advocacy staff from Brussels and Washington DC, as well as other key industry leaders will address the EHS regulatory challenges facing semiconductor manufacturing in 2026 and beyond. Presentations will allow for questions, discussions, and planning for taking collective action to strengthen semiconductor manufacturing.  Tentative topics include:US regulatory landscape under second Trump Administration and global impactUS State-level legislationEurope: PFAS restriction, REACH restriction, packaging and packaging waste regulation, GENESIS Consortium, and more.PFAS recyclingStockholm ConventionEmerging regulations in AsiaSupply chain transparencyUS EPA Technology Transition Rule (HFC Phasedown)US EPA TSCA New Substances Risk EvaluationPlasticizers and flame retardantsMark your calendar to attend, network, and strategically prepare your company. Register today. EHS Summit LocationSEMI 673 South Milpitas Ave. Milpitas, CA 95035James Amano is Senior Director, EHS at SEMI

Per- and polyfluoroalkyl substances (PFAS) are a large class of thousands of synthetic chemicals that are used throughout the semiconductor industry in the form of gases, liquids, and solid high-molecular weight polymers, due to their wide range of physical and chemical properties. PFAS contain carbon-fluorine bonds, which are one of the strongest chemical bonds in organic chemistry, allowing them to resist degradation and to cover long distances away from the source of their release.In recent years, the high persistence of PFAS in both the environment and the human body has encouraged the European Chemicals Agency (ECHA) to launch a PFAS restriction proposal aiming to regulate and eliminate their use over the next few years. The proposal is currently under assessment by ECHA’s scientific committees for Risk Assessment (RAC) and for Socio-Economic Analysis (SEAC).PFAS in the Semiconductor Industry The exceptional physiochemical properties of PFAS provide them a high degree of functionality in semiconductor manufacturing across the entire supply chain, and often the combination of their properties allows manufacturers to satisfy multiple and overlapping technical requirements.While the industry recognizes the importance of transitioning away from PFAS, and research to that effect is ongoing, current technological limitations do not allow the industry to manufacture semiconductors without the use of PFAS or to discover scientifically viable alternatives that can effectively substitute their use.At this point in time, no known alternatives exist for most of the uses of PFAS by the semiconductor industry. Alternative substances must be researched, invented and potentially applied into mass production to be recognized as viable alternatives. Many different pathways will have to be explored as PFAS are currently used across the entire supply chain for over 1,000 semiconductor applications, including articles, support equipment and fab operations, or as process chemicals.SEMI Europe—European Semiconductor Industry Association (ESIA) PFAS Research Workshop Considering the criticality of the PFAS issue for the semiconductor industry, SEMI and the European Semiconductor Industry Association (ESIA) have greatly strengthened their joint advocacy efforts over this past year concerning the ECHA’s PFAS restriction proposal.In this regard, SEMI and ESIA successfully organized a workshop in October 2023 with the relevant representatives of the European Commission (DG GROW, DG ENV, DG CNECT and DG RTD) to present and discuss in-depth the key technical evidence for the use of PFAS is the semiconductor sector. The discussions built upon the extensive technical evidence that was presented by SEMI and ESIA in their respective submissions for the six-month PFAS consultation facilitated by ECHA.Following the successful execution of this first workshop, there was a keen interest from the European Commission to enquire further upon the current state of play of research and development efforts in the field of PFAS detection, abatement, capture and destruction, circularity, recycling and alternativesFor this reason, after the first workshop, ESIA and SEMI collaborated to develop and deploy a joint PFAS Survey aimed at identifying the research priorities in PFAS from the perspective of their member companies. Based on the survey outcomes, the associations compiled the SEMI–ESIA PFAS Research Roadmap and officially presented it to the representatives of the European Commission during a follow-up workshop on 13th June 2024. Discussions at the workshop focused on the key research priorities for the semiconductor industry to discover potentially viable alternatives to the use of PFAS. In the upcoming legislative period, SEMI Europe will continue to engage with relevant stakeholders to contribute to the political debate and encourage a legislative framework that can enhance sustainability across industrial supply chains while preserving Europe’s technological competitive advantage. Get InvolvedGet involved in the SEMI PFAS Working Group! The SEMI PFAS Working Group is composed of industry technologists from leading companies across the global semiconductor manufacturing supply chain. The working group meets regularly to share intelligence and develop strategies to earn exemptions and/or extensions from regulators. Join SEMI in this crucial effort to enable the industry to continue manufacturing chips vital to the prosperity of the world by contacting [email protected]. Stefano Orlando is Manager Advocacy and Public Policy at SEMI Europe.

SEMI Europe's ongoing collaboration with key European industry players and governmental authorities on legislation such as the European Chips Act and critical topics including workforce diversity, sustainability, and supply chain resilience are crucial to the region’s future technological strength.

In response to the PFAS Low Volume Exemption (LVE) Stewardship Program recently established by the U.S. Environmental Protection Agency (USEPA), the SEMI PFAS Working Group (WG) is focused on identifying strategies that minimize supply chain risks and impacts to downstream users.

Semiconductors play an essential role in modern society by enabling ground-breaking technological advances. The manufacture of high-volume and advanced semiconductors requires the use of fluorinated chemicals known as PFAS. Representing the voice of SEMI members, I explained the important role of these substances and their “essential use” in the semiconductor manufacturing supply chain at a Chemical Watch conference for industry and European Union decision-makers on 3rd of December 2020.In order to achieve the European Green Deal’s zero pollution ambition for a toxic-free environment, the European Commission announced in its recently published Chemicals Strategy for Sustainability its intention to restrict the use of the most harmful chemicals, except in cases where they are deemed essential for society. Per- and polyfluoroalkyl substances – known as PFAS – are the first group of chemicals facing regulatory scrutiny on this basis. This begs the question: What chemicals should be characterized as essential for society and what uses will they encompass? The key and enabling role of semiconductors in modern lifeSemiconductors are essential and ubiquitous in our lives. They are integral to enabling modern society to function – driving advancements in mobile communication technologies for the smartphones and computers that help us work more efficiently and connect us with our loved ones. These benefits have never been more evident than in 2020 with billions of people finding themselves working and studying remotely and safely from home.At the same time, technologies relying on semiconductors have been vital in the effort to combat COVID-19 – in ventilators, medical imaging devices and digital healthcare solutions. In addition, semiconductors will also enable the next leap in society to Industry 4.0 and as essential building blocks in connected and electric vehicles, artificial intelligence (AI) and quantum computing.The Commissioner for Internal Market, Thierry Breton, has highlighted the strategic importance of semiconductors in achieving European digital sovereignty (for instance, in his speech at Hannover Messe Digital Days), and the EU’s New Industrial Strategy[1] also points to the importance of semiconductors and microelectronic systems. What must also be appreciated are the cost and complexity of producing these valuable technologies. Setting up a cutting-edge fabrication plant with the hundreds of pieces of semiconductor manufacturing equipment typically required can cost around €15 billion.[2] A single semiconductor manufacturing tool typically consists of millions of articles, and a typical fab may house several hundred pieces of equipment. Furthermore, according to SEMI estimates, the fabrication of semiconductor wafers requires approximately 500 highly specialized process chemicals. In many cases, these processes, equipment and facilities rely on the unique properties offered by PFAS.“SEMI has worked diligently to highlight the strategic importance of semiconductors in achieving European digital sovereignty, and we are pleased that the critical role of microelectronics has been fully recognized by the EU and Member States. Fluorinated chemicals are essential for semiconductor manufacturing. "These specific chemicals are necessary due to their unique properties, and no alternatives are currently available that can adequately provide the functional properties required in semiconductor manufacturing. The essential use concept, therefore, must enable technological innovation, must apply across the entire supply chain, and must enable EU’s critical infrastructure and strategic objectives.” What are PFAS, and why and where are they used in semiconductor manufacturing?PFAS are a broad and highly diverse group of substances with unique properties and characteristics. The Organisation for Economic Co-operation and Development (OECD) has compiled a list of approximately 4,700 substances,[3] a handful of which are used in the semiconductor manufacturing industry. These very specific chemicals are necessary due to their unique and unparalleled properties that enable them to be used in the demanding conditions of semiconductor manufacturing.Semiconductor chemicalsAt the very core of semiconductor manufacturing is the photolithography process, where microscopic geometric patterns are transferred onto a film or substrate. Photolithography specialty formulations containing fluorinated compounds are used in various steps of this process to ensure quality and reduce the probability of defects. PFAS must be used due to their low surface tension and compatibility with other chemicals. PFAS are typically no longer present in the finished product. However, there are applications where PFAS are present in the final semiconductor device, particularly in imaging semiconductors used in cameras, displays and some medical devices, amongst others. Semiconductor manufacturing equipmentPFAS are also essential to semiconductor manufacturing equipment and factory infrastructure. The exceptional combination of their heat and chemical resistance and their chemical inertness allows fluoropolymers to be used both in equipment components (tubing, gaskets, containers, filters, etc.) and lubrication (such as various oils and greases). These same properties are also needed to ensure the functioning of the surrounding infrastructure. Finally, some fluorinated gases, which are already regulated by specific legislation,[4] are used as refrigerants and to clean the facilities.These are a handful of examples of how PFAS are used in semiconductor manufacturing. Today, there is no other way to undertake these processes or to build semiconductor manufacturing equipment without PFAS. No alternatives are currently available that can adequately provide the functional properties required. Even if alternative chemicals and technologies were discovered today, due to the extremely complex qualification process throughout the value chain, it would take another 15 years to deploy them in high-volume manufacturing. Therefore, continued access to PFAS is a prerequisite for high-volume and advanced semiconductors. Lack of continued access to PFAS could lead to an inability to produce and supply the EU with semiconductor manufacturing technology.How should we think about essential uses?Regulators have started to think about what uses of PFAS are essential and in which cases their use should be allowed. In developing this concept, there are a few aspects to keep in mind.Essential use must enable, not hinder, technological innovationFirst and foremost, the essential uses concept should enable continued technological innovation instead of acting as a hindrance. Semiconductors and manufacturing technology are constantly evolving and becoming more diverse to help meet increasing societal demands. What we see as innovative today may be commonplace in the future, while future innovations may be unimaginable today. We must therefore be careful not to accidentally limit our future potential for innovation.Essential use must apply across the entire supply chainSecondly, classifying a use as essential should apply throughout the entire supply chain. We must, for example, avoid defining semiconductors as essential while classifying the semiconductor manufacturing equipment and chemicals used to produce semiconductors as not essential. In the semiconductor manufacturing supply chain, where one manufacturer can have up to 16,000 suppliers, this risk is evident.[5]Essential use must enable critical infrastructures and the EU’s strategic objectivesFinally, we should keep Europe’s societal priorities in mind. The EU needs to be able to maintain and protect its critical infrastructures. Similarly, we should not lose sight of the EU’s strategic objectives of a green and digital Europe.Semiconductors, in conjunction with their corresponding manufacturing equipment and chemicals, are essential technologies in everyday life and the backbone of the EU’s strategic value chains. Manufacturing semiconductors is a very expensive and complex process that would not be possible without the unique properties of PFAS, making them essential to achieving the EU’s strategic objectives today – whether the European Green Deal or digital autonomy – and in the future. Therefore, we must ensure that essential uses will enable the continued use of PFAS in semiconductor manufacturing.The SEMI presentation delivered at the Chemical Watch event can be accessed here.Emir Demircan is director of Public Policy and Advocacy at SEMI Europe.[1] “The EU will also support the development of key enabling technologies that are strategically important for Europe’s industrial future. These include robotics, microelectronics, high-performance computing and data cloud infrastructure, blockchain, quantum technologies, photonics [etc.]”[2] Emerging technologies in electronic components and systems (ECS) Opportunities Ahead – A study by DECISION, 2018 for the European Commission[3] Available here[4] Regulation (EU) No 517/2014, “F-Gas Regulation”[5] SIA Nathan Associates, 2016, https://www.semiconductors.org/wp-content/uploads/2018/06/SIA-Beyond-Borders-Report-FINAL-June-7.pdf

The semiconductor industry must do far more to educate the electronics supply chain on the subtle differences among various fluoropolymers, 30 SEMI member companies learned in an October 13 webinar organized by SEMI to help maintain a unified voice on the critical importance of per- and polyfluoroalkyl substances (PFAS) in semiconductor manufacturing. At the same time, producers and customers of the substances used in chipmaking should work more closely together to steer clear of adopting policies that could limit the availability of safe fluoropolymers and the semiconductor industry’s ability to use them in the future.The insights were offered by representatives from the Performance Fluoropolymer Partnership – a group within the Washington, D.C.-based American Chemistry Council – on per- and poly-fluorinated substances including fluoropolymers. The Council is an industry trade association representing American chemical companies. Following are other key takeaways from the webinar. Fluorinated polymers and non-polymers are commonly found in components used in semiconductor manufacturing such as fittings, valves, tubes, O-rings, wafer carriers, filtration media, high purity air filters, greases and lubricants. The substances are ideal for use in corrosive chemicals, high temperatures and other harsh environments and are found in a variety of electro-technical components such as potentiometers, wiring, printed circuit boards and Lithium-ion batteries. Fluoropolymers are a diverse family of plastics also widespread in modern life, with applications ranging from food packaging and non-stick coatings on kitchen pans to rechargeable batteries for electric vehicles. The term PFAS (per- and poly-fluoroalkyl substances) covers more than 4,700 chemicals with diverse physical, chemical, environmental and biological properties and impacts. There are also significant differences among their chemical compositions. A careful appraisal of their risks and impacts should take into account any potentially hazardous properties, toxicity levels, their prevalence in the industry, and whether substitutes are readily available. Growing pressure from regulators worldwide threatens future access to fluorinated chemicals, increasing the importance of raising awareness on how to distinguish groups of chemicals and encouraging a measured approach towards eliminating only chemicals carrying the greatest risk. Fluoropolymer producers and opponents of the chemicals must look past their divergent interests to work together to voice common concerns to regulators. Various SEMI working groups respond to public consultations when opportunities to present the semiconductor industry’s position arise. Individual group members communicate both among each other regarding new regulatory developments and also with external constituents through SEMI about the importance of chemicals to chip manufacturing. As with other sectors, the semiconductor industry continuously seeks to “green” its manufacturing processes. SEMI believes the commitment of the supply chain to these efforts is crucial to protecting the industry’s interests and driving innovation.Olivier Corvez is senior manager of Environment, Health, Safety and Sustainability at SEMI.