EU regulation update: What could impact the industry next?

By Rania Georgoutsakou, director of Public Policy for Europe, SEMI

In a global industry, monitoring regulatory developments across different regions can be a challenge. Add to that the additional complexity of communicating with a (global) supply chain, then consider that each company has to individually reach out to its suppliers and customers. This results in numerous communications on the same issue up and down the supply chain, and the benefits of industry collaboration within associations such as SEMI become clear.

To help companies keep up with the latest developments in the EU, here’s a list of recent and upcoming regulatory initiatives and how SEMI member companies are collectively addressing these:

  • SEMI FAQ – EU F-Gas regulation and semiconductor manufacturing equipment
  • Review of EU Machinery Directive now underway
  • EU PFOA restriction under discussion
  • 2016 EU Blue Guide is available

A SEMI webcast on EU regulatory developments (March 2016) provided a more detailed overview of these and other developments and how companies should prepare – the webcast is available to view for SEMI member companies only, please click here and select the “EU Regulation Webcast”.

Manufacturing equipment containing pre-charged chillers – new SEMI FAQ provides guidance on how to comply with EU F-Gas law

The EU F-Gas regulation that entered into force in January 2014 creates new restrictions on placing on the EU market pre-charged chillers containing certain fluorinated gases (F-gases).

A new SEMI FAQ on the EU F-Gas regulation provides guidance on what this law is about, how it impacts semiconductor manufacturing equipment and what steps companies importing affected equipment should be taking to ensure compliance.

If your company is importing semiconductor manufacturing equipment containing pre-charged chillers into the EU, then you need to make sure you can account for the f-gases in the chiller under the new F-Gas quota system that the law has established, by obtaining an ‘authorisation’ from a ‘quota holder’ and registering in the ‘EU HFC Register’.

For more details and compliance timelines, check out the SEMI FAQ.

EU Machinery Directive – review now underway – have your say!

The EU Machinery Directive sets out the basic requirements machines must satisfy in order to be placed on the EU market and is a major piece of EU law for semiconductor manufacturing equipment.

The review is part of the regular EU regulatory review process to ensure legislation is ‘fit for purpose’ and does not automatically imply that the Machinery Directive will be revised. It is being run by an external consultant and a final report is expected in April 2017.

The focus of the review will be on 9 product categories, including machines for metal working, engines and turbines, robotics and automation and will also explore whether there are discrepancies in the interpretation of the directive between various member states and to what extent it is aligned to other pieces of legislation.

SEMI is putting together a working group to contribute to review of the EU Machinery Directive. If you are a member company and want to get involved, please contact gourania@semi.org

PFOA restriction under discussion – SEMI requests derogations for the industry

The EU is currently drafting a law to restrict the manufacture, use and placing on the market of PFOA, its salts and PFOA-related substances under EU REACH. The restriction would apply both to substances and mixtures and to articles containing these substances.

SEMI has been calling for a derogation for substances and mixtures used in photolithography processes and for articles contained in semiconductor manufacturing equipment.

SEMI has collected and submitted evidence to substantiate members’ recommendations for:

  • a derogation period of at least 10 years for semiconductor manufacturing equipment, to allow equipment manufacturers to communicate with their the supply chain, identify components potentially containing restricted substances, source substitute parts that are tested and validated and requalify the equipment.
  • non-time-limited derogation for spare parts for legacy semiconductor manufacturing equipment, i.e. equipment that was already on the EU market before the restriction entered into force and before the derogation for semiconductor manufacturing equipment expires.
  • non-time-limited derogation for second-hand semiconductor manufacturing equipment, to ensure that companies can still import used equipment from outside the EU or from another EU member state.

SEMI has also voiced its concerns around the proposed concentration limits and the non-availability today of standardized practicable analytical methods that can be applied to a variety of materials to test whether an article would comply with the restriction.

The EU proposed restriction will be published in the next month and the final decision on the restriction is expected by the end of 2016.

Product regulatory compliance in the EU – 2016 Blue Guide now published

The Blue Guide provides guidance on how to implement EU product rules, including for example the EU Machinery and EMC Directives. A 2016 revised version is now available to download – click here.

The Blue Guide addresses:

  • what constitutes placing a product on the EU market
  • obligations of the various actors in the supply chain (manufacturer, importer, authorized representative etc.)
  • product requirements
  • conformity assessment
  • accreditation
  • market surveillance carried out in the EU

For an overview of SEMI’s advocacy work in Europe, please click here.

To find out more and get involved, please contact gourania@semi.org

Join us for the 10th SEMI Brussels Forum – the industry’s major annual event bringing together company executives and decision-makers to discuss opportunities for the micro/nano-electronics industry in Europe: www.semi.org/BrusselsForum

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