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As the United States government has expanded semiconductor-related export controls, companies in the global electronics manufacturing and design supply chain have had to spend considerable time and effort navigating restrictions and managing significant new uncertainties emanating from recent policies. On November 9, SEMI submitted comments to the Department of Commerce’s Bureau of Industry and Security (BIS) urging the agency to proceed cautiously and adopt regulatory best practices and microelectronics industry recommendations to ensure that its identification of foundational technologies does not restrain U.S. innovation and exports without furthering essential U.S. national security interests. The comments specifically respond to the August 27 Advance Notice of Proposed Rulemaking (ANPRM), Identification and Review of Controls for Certain Foundational Technologies. The Export Control Reform Act (ECRA) of 2018 required BIS identify certain emerging and foundational technology that is “essential” to U.S. national security and requires such technology to be controlled to China and other nations subject to a U.S. arms embargo. Congress did not provide a specific definition for emerging or foundational technology, nor the term essential, further complicating the process to identify such technology.BIS has already implemented or proposed several emerging technology controls and the ANPRM starts the process to identify potential foundational technology controls. The SEMI comments focus on the fundamental question of how to define foundational technology, and are organized into three main sections: Requirements of ECRA Guidance from ECRA Regulatory best practices and industry recommendations Applying the statutory requirements and guidance, together with best practices and recommendations, to the identification of foundational technology indicates that most semiconductor-related technology, particularly semiconductor manufacturing equipment and materials, should be outside the bounds of the foundational technology initiative. In general, most technology related to semiconductor devices, manufacturing equipment, materials and design software is not essential to U.S. national security and, in cases where such technology does present material national security issues, it is generally subject to the U.S. list review process and multilateral controls. This technology is widely available outside the United States and due to substantial foreign availability, unilateral U.S. controls on such technology are likely to be ineffective in limiting its proliferation and harm U.S. development of or threaten U.S. leadership in this technology.While the SEMI comments focus on the effort to identify foundational technology, the recommendations and best practices apply in all export control contexts. Several of the statements pertain to policy in ECRA, including its imposition of controls to further specific essential U.S. national security interests only after full consideration of their impact on the economy.Other statements derive from factors ECRA requires BIS to consider, such as not seeking to control technology that’s already available outside the U.S. and not imposing controls that would harm U.S. technological development or leadership. An additional key factor is not imposing controls before multilateral controls are agreed to, nor when it is unlikely the relevant multilateral regimes will adopt similar controls, as is likely for technology that has been decontrolled by a regime.Finally, regulatory best practices suggest that technology-based controls should not be imposed when more targeted end-use or end-user controls can address national security concerns and duplicative controls in addition to recent, significant expansions of existing controls are unnecessary.SEMI is pleased to work with the U.S. Department of Commerce and other regulatory agencies, providing industry data, trends and perspectives to ensure export controls effectively serve national security interests without undue harm to technological development and leadership in this dynamic, globally competitive industry.Ways to Stay Connected and Learn MoreSEMI is committed to serving the global electronics manufacturing and design supply chain and present the collective voice of members to governments worldwide.The SEMI Global Update weekly newsletter provides updates on advocacy issues and technology trends and is available to all.Additionally, SEMI hosts live and virtual events that offer analysis and insights of geopolitical trends by industry experts, with the next opportunity to participate coming on December 3 with the SEMI CEO Webinar: Analyzing the Impact of the U.S. Election on the Microelectronics Industry.Joe Pasetti is Vice President of Global Public Policy and Advocacy at SEMI.
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In many ways it feels like we’ve turned back the hands of time. We are staying at home, playing board games with the family. Outdoors, we can view mountains not seen in decades – air pollution has dropped nearly 20 percent. Neighbors we haven’t met are out walking, a lot. Traffic is relatively sparse.We’re staying up late, sometimes even getting up early, for calls with all regions. Some of us have temporarily suspended our use of cleanroom masks – but now wear them everywhere we go outside of the house. And through virtual meetings, I see I’m not the only one who let the beard grow. Who would’ve thought we’d be able to so quickly and completely change our habits?Clearly, the usual distractions that fill most of our lives have given way to a temporary pause. We have time to reflect, and perhaps gain even greater perspective. I hope that’s been a good thing for you.Through virtual meetings, we seem to be getting access to people not typically in our circle of influence – both up and down the organizational ladder. This pleasant surprise seems to be helping to create a valuable acceleration in how the industry community interacts and progresses.As a testament to the strategic importance of our industry, the fabs continue to produce. This is due in great part to the standards, technologies and their resulting applications that enable those operations. Many parts of our industry supply chain became officially designated as essential businesses. Whether or not we stayed home from the office, we’ve continued to work on our roadmaps for growth beyond the current lull.Empowered by 50 years of technology legacy, we are again demonstrating the capability to manage disruption through collaboration. This is the signature of our industry’s highly regarded business culture. Among what we have learned is that this pandemic has made all of us more vulnerable in a variety of ways, and in turn has accelerated our unity as an industry community like never before.This month, as I brainstormed with a set of industry execs during one of countless Zoom meetings, it was clear that when they gather, they want more than a repackaged version of everyone else’s usual messages about this unusual year.While this type of year certainly wasn’t what we had in mind when we began to construct ways to mark this 50th year of SEMICON West, we’ve taken the bull by the horns and begun to blaze a new trail. The consensus within the industry is that SEMI’s constant, measured communication is netting an increased, and growing, level of trust among our collective, global group that may serve as one of the silver linings of this irregular year.As a result, we’ll lay a new road with the first – and possibly not the last – Virtual SEMICON West. For this inaugural digital format, we’ve secured a set of visionaries offering both legendary and evolutionary talents alike to reveal what we can expect during the next few years. It’ll be unlike any other such gathering before, and there’ll be something for everyone.Despite the pause in time we’ve experienced during our isolation of these recent weeks, the timeless value of collaboration marches on. I look forward to joining you at Virtual SEMICON West, July 20-23.Dave Anderson is president of SEMI Americas.
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Since the beginning of the COVID-19 outbreak earlier this year, the world has been flocking online – to connect, to share stories, and, for those who can, to continue to work to help keep the wheels of economies turning. With its shift away from in-person events, the SEMI Foundation, too, has found new ways to connect with members and talent. We have started to develop online content for high-school and university students to maintain engagement with these vital pools of future talent. As we build our online presence, we will also explore providing support for reskilling employees, veterans and other target hire groups to help meet microelectronics industry’s talent needs.This strategic shift involves repurposing and transforming existing programs. One key focus area as we evolve our work has been SEMI High Tech U (HTU), a hands-on industry exposure program the SEMI Foundation launched in 2001. The program aims to gather high-school students at member company work sites to learn about the science behind semiconductor technology and various career paths. We are working to offer this career education opportunity online to better connect with students and educators all over the world, regardless of their proximity to a member company. This new guided online journey through the manufacture of a silicon chip will allow users to learn about the science, technology, equipment and companies needed to create this amazing device that is the heart of our digital world.The SEMI Foundation’s open houses catering to university students are also going online. The virtual events will give students a chance to learn about the critical technologies emerging from the microelectronics industry and available career opportunities. They will also be able to submit their resumes for open positions at our member companies.We’re excited as we gear up to launch these online programs in order to expand our reach and impact and to support the critical workforce development needs of our member companies. As we begin to expand our online content, we will be recording our educational webinars and gathering testimonials from corporate leaders and offering both as free resource to members, students and potential hires. These digital resources will help our members share talent development best practices and give students deeper insights into the industry.If you would like to support these initiatives as the SEMI Foundation continues to help the industry attract, develop and retain talent in ways that no single member company can alone, you may do so in a number of ways: Volunteer to review educational content for accuracy and relevance Sign up to be a speaker or panelist at upcoming virtual events Share industry informational videos Highlight industry technologies that are making a difference in the world Showcase how your company is addressing STEM education and workforce development Sponsor an upcoming SEMI Foundation workforce development event To get involved, please contact Shari Liss, executive director of the SEMI Foundation, at [email protected].
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