SEMI & EU REACH - impact on semiconductor manufacturing equipment Rania Georgoutsakou

Transcription

1 SEMI & EU REACH - impact on semiconductor manufacturing equipment Rania Georgoutsakou Director Public Policy for Europe, SEMI

2 Outline Introduction to semiconductor manufacturing equipment Product complexity (number of potential articles) Nature of supply chain Sector s control over the supply chain Substances in articles SEMI understanding and questions about ECJ ruling: How to enforce definition of article? Questions that have been raised Proposals that have been floated Restrictions on substances in articles PFOA How SEMI uses PFOA in articles SEMI concerns about proposed restriction Sustainable industry engagement in regulatory initiatives 2

3 About semiconductor manufacturing 3

4 Exponential technological advances the nanometer scale - a human hair is 100K times wider than a 7nm transistor controlled cleanroom environment 2 nd most R&D intensive industry (2015 EU Innovation Scoreboard) EU Key Enabling Technology (EU, 2013) 4

5 The Electronics Supply Chain 5

6 Semiconductor manufacturing a glance High mix Low volume Highly customized High Value Long service life sold onto many users Subject to EU regulations (e.g. Machinery Directive, REACH) Large scale stationary industrial tools within large scale fixed installations Subject to industry-wide standards Operate under strict conditions (cleanroom environment) 6

7 Clean room environment 7

8 Semiconductor Manufacturing Equipment HIGH MIX s s of direct components in one product. Many more indirect components/articles. Countless homogeneous layers 8

9 Industry standards Drafted, voted and reviewed by industry Cooperation across the supply chain Regularly reviewed to reflect new technological and regulatory developments

10 SEMI EHS Guidelines by Topic Equipment S2 Semiconductor manufacturing equipment S26 Flat Panel Display manufacturing systems Equipment related S1 Safety labels S3 Process liquid heating systems S6 Exhaust ventilation S13 Manuals S14 Fire risk assessment and mitigation S17 Unmanned transport vehicles S22 Electrical safety design S28 Robots and load ports safety Environment S12 Equipment decontamination S16 Reduction of environmental impact at end of life S23 Energy, utilities, and materials conservation S29 Fluorinated greenhouse gas emission Chemicals, Gases, & Distribution S4 Chemical cylinder separation S5 Flow limiting devices S18 Silane flammable silicon compounds S25 Hydrogen peroxide storage & handling Personnel S8 Ergonomics S19 Installation, maintenance, and service personnel training S21 Worker protection S24 Multi-employer work areas Other S7 Evaluator qualifications S10 Risk assessment/evaluation S27 Evaluation reports

11 Semiconductor manufacturing is global 11

12 Examples of SEMI members across the supply chain 12

13 The nature of the supply chain 13

14 Substances in articles 14

15 What is an article? Insulated electric cable: PVC tube is produced separately and pulled over wire -> cable is composed of 2 articles PVC is mixture poured over wire -> cable is 1 article Question: is there a test to show how the cable was manufactured? More questions: Sheet composed of carbon fibers fixed together by a resin mixture -> is each carbon fiber is an article? Example of what is not an article? (i.e. shape etc. resulting from manufacturing process is not more important than chemical properties) 15

16 Applying ECJ ruling: How Many Articles in this Tea Kettle? 16

17 The order of manufacturing is important A corrosion resistant paint is needed between a bracket, and the frame to which the bracket attaches with screws. 1. The paint is 19% w/w of a candidate list substance (CLS) 1 gram of paint is needed in the assembly which dries to contain 0.2 grams of the CLS. Some non-cls substances are lost from the paint due to evaporation. 2. The bracket weighs 50 grams. 3. The frame weighs 1,500 grams. 4. The 2 screws weight 5 grams each (= 10 grams) Case A - Case B - The necessary amount of paint is applied to the bracket and left to dry. The resulting article is 0.2/50.2 (or 0.4% w/w) CLS. When the painted bracket is then assembled to the frame, it is a complex product containing an article exceeding the CLS threshold. The necessary amount of paint is applied to the frame and left to dry. The resulting article is 0.2/1,500.2 (or % w/w) CLS. When the unpainted bracket is assembled to the painted frame, it is a complex product without any article exceeding the CLS threshold.

18 Issues raised by ECJ ruling Common definition of what is an article Common understanding of number of articles in a complex product >> must rely on information provided through the supply chain Communication: supply chains are global - EU REACH is regional Complying with information requirements while addressing IP/CBI issues Common understanding of most appropriate format for communicating information Compliance for used equipment 18

19 Various stakeholders reactions to ECJ ruling Enforcement moratorium REACH impact on competitiveness Supply chain due diligence ECHA-hosted website on prioritized components ECHA-hosted component database Proportionality Cut-off limits Peanut principle Standardised information communication format Information re end-of-life/waste stage and overlap with other EU legislation Impact on restrictions (Annex XVII) to articles and any part thereof? 19

20 Restrictions on substances in articles - PFOA 20

21 Use of PFOA in articles in semiconductor manufacturing equipment May be used in components/sub-components: Chemical containers Tubing Gaskets Ductwork Filtration systems Insulated conductors Small mechanical assemblies Various coatings >>> Supply chain communication still ongoing to identify potential use and presence 21

22 Development and validation process V-Model of Product Development, Verification, and Validation 22

23 SEMI concerns over PFOA restriction in articles Testing methods not available for all uses at time of restriction proposal Reliance on supply chain communication SEMI request for 10-year derogation Got 5 years possibility for review? Articles or any parts thereof complete ban but what about degradation telomers? Potential of industry PFOA-free certification systems 23

24 Sustainable management of regulatory initiatives 24

25 Global regulatory landscape 25

26 Overview of regulatory initiatives impacting SEMI members REACH PFOA, its salts and PFOA-related substances POP Convention EU proposal to restrict PFOA, its salts & PFOArelated compounds RMOA by BAuA for PFHxA Basel Convention Technical Guidelines EU F-Gas and SEMI FAQ for compliance Conflict Minerals Substance evaluation methodology under RoHS On hold: NMP & RCF 26

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28 Thank you! Rania Georgoutsakou