EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren

Europaudvalget 2022-23 (2. samling)
EUU Alm.del
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Critical uses of PFAS chemicals and materials in the semiconductor industry

November 2022

To whom it may concern,

Five of the members of the World Semiconductor Council (Semiconductor Industry Associations in

China, Korea, the United States, Chinese Taipei and Europe) as well as SEMI submit for consideration

by RIVM newly obtained information that is related to critical and essential uses of PFAS chemicals

and materials in several different semiconductor manufacturing processes.

The definition of a PFAS is now very expansive, encompassing not only the highly specialized

chemistries that are known to be essential to photolithography applications, but also chemicals

required for use in other applications, including applications within semiconductor manufacturing

equipment, facility support and chemical delivery systems, as well as those required for use within

finished semiconductor products. For the majority of these applications, viable non-PFAS substitutes

have not been identified nor developed as needed to enable substitution of current PFAS uses

required for use in the semiconductor manufacturing process. As such, the Associations of the WSC

intend to make clear that to ensure the ongoing availability of semiconductor products, wide-ranging

derogations will need to be provided to the semiconductor industry to enable ongoing manufacturing

and to allow for sufficient time to identify, develop and implement non-PFAS alternatives wherever

substitution may be possible.

Importance of Semiconductors

Semiconductors are used in many applications that are essential to everyday life and security,

including consumer electronics, healthcare, transportation, communications, and military

applications. Semiconductors are a key enabler of low carbon and energy efficient innovative

solutions that reduce our dependence on fossil fuels and minimize emissions. Semiconductors help

reduce society's environmental footprint, by optimizing energy usage in transportation,

manufacturing, services, and consumer products. Semiconductors facilitate the transition towards a

decarbonized economy while simultaneously contributing to an innovative and sustainable and safer

society. Semiconductor devices are also a key enabler of greenhouse gas reductions within other

industries and services, such as energy, manufacturing, agriculture, land use, construction, and traffic

management

An Introduction to the Semiconductor Process

The manufacturing of semiconductors is a highly complex process that requires the building of uniform

and minute transistors that include features that may be only a few atoms or molecules wide, as exact

replicates numbering in the billions across the surface of a wafer. A single wafer may go through one

or more of these process steps multiple times before processing is complete. A manufacturing process

of such high precision is only possible through use of a multitude of chemicals, materials and

From

Digital technology can cut global emissions by 15%. Here’s how,

World Economic Forum, 2019

https://www.weforum.org/agenda/2019/01/why-digitalization-is-the-key-to-exponential-climate-action/

EUU, Alm.del - 2022-23 (2. samling) - Supplerende svar på spørgsmål 49: Spm. om, hvilke interessenter, virksomheder mv. ministeriet har været i dialog med i forbindelse med ønsket om at indføre et forbud imod anvendelsen af PFAS, til miljøministeren, kopi til udenrigsministeren

sophisticated manufacturing equipment that provide the unique performance characteristics capable

of meeting demanding performance requirements.

Introduction to the Essential Use of PFAS Chemistries and Materials

The carbon fluorine bond is one of the strongest polarized single bonds known and provides essential

function due to their unique ability to simultaneously provide for multiple performance requirements

that are critical for manufacturing

. PFAS chemistries and materials are now present in as many as a

thousand individual use applications due to their inherent characteristics, with key examples listed

below:

Low refractive index and other optical properties

Ability to generate superacids

Low surface energy

Unique solubility

Stability and Chemical Inertness

Low flammability

Low outgassing and/or particle shed

The list above is not exhaustive, and further examples can be provided as necessary.

The SIA Semiconductor PFAS Consortium

is comprised of semiconductor manufacturers and

members of the supply chain including chemical, material and equipment suppliers that have come

together with the intent to better inform PFAS related public policy and legislation through the

collection and sharing of technical data, including:

- Identification of critical and essential PFAS uses,

- Application of the pollution prevention hierarchy to, where possible: reduce PFAS

consumption or eliminate use, identify alternatives, and minimize and control emissions,

- Identification of research needs, and

- Development of socioeconomic impact assessments

More detailed technical information is forthcoming and will be ready for sharing soon.

An Overview of New PFAS-Use Information Compiled by the SIA Semiconductor PFAS Consortium

Much new information has been generated since the Consortium was convened in January of 2022,

which can be summarized as detailed below.

PFAS chemistries and materials are used extensively in the semiconductor manufacturing process and

generally fall into three categories of use:

Christopher K. Ober, Florian Käfer, Jingyuan Deng, “The essential use of fluorochemicals in lithographic

patterning and semiconductor processing,”

J. Micro/Nanopattern. Mater. Metrol. 21(1), 010901 (2022), doi:

10.1117/1.JMM.21.1.010901, available at

http://dx.doi.org/10.1117/1.JMM.21.1.010901.

Public Statement of the Semiconductor PFAS Consortium

https://www.semiconductors.org/public-statement-of-the-semiconductor-pfas-consortium/

PFAS chemistries and materials used in manufacturing equipment and infrastructure,

including heat transfer fluids and refrigerants, lubricants, sealants, and fluoropolymers used

in manufacturing chambers, water/chemical conveyance systems and water production and

environmental abatement systems

PFAS chemistries used directly within the semiconductor manufacturing processes, including

lithography photoresists, dry etch and chamber clean gases, surface modification, and other

applications

PFAS chemistries and materials required for incorporation in the final semiconductor

packages that are the products sold by the semiconductor industry

PFAS chemistries and materials are used in perhaps as many as a thousand or more individual use

applications, and for the majority of these applications, potential non-PFAS substitutes are not known

or currently viable.

Estimated Timelines That Would Be Required to Identify and Implement Non-PFAS Alternatives

The semiconductor industry would require a considerable amount of time to identify, develop and

implement suitable non-PFAS alternatives for current use applications to the extent feasible. Because

the semiconductor manufacturing process needs to both maintain and improve the performance of

its products over time, the industry follows a standard method for identifying, developing, and

implementing promising alternative chemicals, materials and technologies. Such activities occur in

stages that include:

- Identification of promising chemistries and technologies as potential alternatives

- Development of potential alternatives into proven manufacturing solutions

- Integration of new manufacturing solutions into new and existing manufacturing processes

- Qualification of new processes to ensure appropriate matching to performance requirements

for each manufacturing step, and

- Demonstration of device performance in end applications ensure minimum requirements are

met in the end-product applications

- Qualification of end product application

Overall, at least 12+ years is required to complete most individual substitution efforts once suitable

alternatives are identified. For the pending PFAS regulatory restriction, this timeline is compounded

by the high number of substitutions that will be required, and the fact that completion of many

simultaneous substitutions will be extraordinarily difficult, if even possible. As such, the Associations

of the WSC believe that a considerable amount of time and effort would be required, and that even

with the allowance of an extended amount of time, achieving the end goal of complete substitution

of all PFAS chemistries and materials may prove to be elusive. Additionally, the effort required to

replace legacy uses of PFAS will

severely limit the industry’s ability to innovate new technologies due

to competing resources.

The Semiconductor Industry Has a Demonstrated Commitment to Sustainability

The Semiconductor industry has made notable voluntary commitments to improve its sustainability

in, such as the voluntary phase out of PFOS and PFOA

, and to achieve GHG reductions. It is notable

that these efforts were voluntary in nature. Despite the relatively limited scope of effort involved,

compared to the larger effort that substitution of the entire class of PFAS will entail, more than 10

years was required to substitute PFOS and PFOA, while the effort to reduce GHGs started over 25

years ago and remains a work in progress.

Thank You

The associations would like to thank RIVM for their consideration of these comments. We welcome

any further consultation that may be desired to enable further common understanding of the

industries need for essential PFAS use applications. For any inquiries, please contact: Mathias Müller

([email protected]).

Sincerely,

Endorsed by the Semiconductor industry associations in:

China

Chinese Taipei

Europe

Korea

And by SEMI

WSC Joint Statement of May 2017, page 25-26 (available at

http://www.semiconductorcouncil.org/wp-

content/uploads/2017/05/21st-WSC-Joint-Statement-May-2017-Kyoto-Final1.pdf