European Electronic Component Manufacturers' Association

EECA

The European Electronic Component Manufacturers' Association represents the common interests of the semiconductor industry in Europe.

Lobbying Activity

Meeting with Andreas Schwarz (Cabinet of Commissioner Ekaterina Zaharieva), Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

13 Jan 2026 · Innovation policy and funding for semiconductors

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and

13 Jan 2026 · Trade agenda and competitiveness of the semiconductor industry in Europe

Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

13 Jan 2026 · The Industrial Accelerator Act, the Chips Act and State aid rules

European semiconductor industry seeks 7.5-year exemption for chemical ban

19 Dec 2025
Message — The organization requests a 7.5-year transition period before banning LC-PFCAs in semiconductor manufacturing equipment. They argue technical constraints and complex supply chains make immediate substitution of these materials impossible.12
Why — This delay would help avoid manufacturing disruptions and support the expansion of European semiconductor production.3
Impact — Environmental interests lose as persistent organic pollutants remain in industrial use for several years.4

European chip manufacturers urge six-year delay for chemical ban

19 Dec 2025
Message — ESIA requests a six-year extension for equipment using restricted chemicals. They argue complex machinery requires years of testing and customer re-qualification.12
Why — A longer transition avoids factory disruptions and costly immediate machine redesigns.34
Impact — Environmental protection efforts are delayed as hazardous chemicals remain in use.56

Semiconductor industry urges EU to modernize trade origin rules

2 Dec 2025
Message — The association recommends keeping the principle of last substantial transformation and product-specific lists. They also request updates to reflect modern manufacturing processes and technological advances.123
Why — Modernized rules would reduce administrative complexity and support the global competitiveness of European companies.45

Semiconductor industry warns against strict EU material recovery targets

6 Nov 2025
Message — ESIA asks the Commission to avoid strict material recovery targets for semiconductors. They argue current technology is underdeveloped and yields contaminated materials.123
Why — Exemptions would prevent high financial costs and maintain European manufacturers' global competitiveness.45
Impact — EU environmental goals for recovering critical raw materials would likely be undermined.6

Meeting with Elisa Roller (Director Secretariat-General)

29 Sept 2025 · Competitiveness of the EU based semiconductor industry

Meeting with Chiara Galiffa (Cabinet of Commissioner Maroš Šefčovič) and Infineon Technologies AG and NXP Semiconductors Netherlands B.V.

1 Sept 2025 · Recent developments on trade and tariffs impacting the semiconductor sector

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology) and European Association Automotive Suppliers and

9 Jul 2025 · Multistakeholder event on European semiconductor policies and investment

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

9 Jul 2025 · Meeting with the Board members of the European Semiconductor Industry Association

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Hanna Anttilainen (Cabinet of Executive Vice-President Stéphane Séjourné) and

3 Jul 2025 · Presentation of ESIA and the semiconductor industry in Europe

Meeting with Damien Levie (Head of Unit Trade) and Infineon Technologies AG and NXP Semiconductors Netherlands B.V.

30 Apr 2025 · Exchange on semiconductor outlook

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology) and ASML Netherlands B.V.

24 Apr 2025 · ESIA & ASML : Exchange on semiconductor outlook

Meeting with Damien Levie (Head of Unit Trade) and ASML Netherlands B.V.

24 Apr 2025 · Exchange on semiconductor outlook

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

23 Apr 2025 · European semiconductors state of play

Response to Technical description of important and critical products with digital elements

18 Apr 2025

Executive Summary Semiconductors are key components of everyday electronic devices that make life easier, safer, more secure, and greener. From ground and air transportation to pass-ports, payment cards, terminals, servers in data centres, desktop computers, sensors, etc., semiconductors are ubiquitous, fulfilling a crucial role in the whole domain of the Cyber Resilience Act (CRA). In the opinion of ESIA members participating in the CRA implementation activities, there is a need to prevent for a disconnect to arise between the intentions of the European Commission and the reality of the semiconductor industry. Two key aspects need to be addressed. First, while industry best practices clearly distinguish between a semiconductor as a product / component with digital elements and the electronic product in which said semiconductor is incorporated, the European Commission does not seem to make this differentiation, as reflected in the proposed CRA legal text. Second, according to the existing industry best practices a given form factor does not determine the level of criticality of the product. However, the European Commission seems to use an interpretation that does not correspond to industry best practices and contradicts the CRAs risk-based approach and principle of proportionality. ESIA is concerned that the above discrepancy may negatively impact the implementation of the CRA and believes an alignment is critical. For the sake of a smooth CRA implementation, ESIA calls on the European Commission to ensure through a clarification in the Implementing Regulation of the CRA that the existing best practices in the semiconductor industry are used.
Read full response

Meeting with Denis Redonnet (Deputy Director-General Trade) and Robert Bosch GmbH and

3 Apr 2025 · Exchange on the implications of recent US trade measures and the broader geopolitical environment on the European semiconductor industry

Meeting with Bernd Biervert (Cabinet of Commissioner Maroš Šefčovič), Dārta Tentere (Cabinet of Commissioner Maroš Šefčovič) and

3 Apr 2025 · Trade relations and economic security

Meeting with Henna Virkkunen (Executive Vice-President) and

3 Apr 2025 · The European semiconductor industry and the review of the Chips Act

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

21 Mar 2025 · European semiconductors state of play

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

5 Mar 2025 · Semiconductor aspects in the Structured Strategic Dialogue on the Future of the Automotive Industry and follow-up on key priorities of European chips policies

Chip manufacturers urge EU to support industry water recycling

26 Feb 2025
Message — The association calls for a regulatory framework that incentivizes investments in water recycling. They request flexible standards for semiconductor production and guaranteed access to water supplies.123
Why — Securing subsidies and priority water access would safeguard their high-tech production capabilities.45
Impact — Environmental advocates may see requested flexibility as a risk to strict water quality standards.6

Meeting with Pierre Chastanet (Head of Unit Communications Networks, Content and Technology)

17 Jan 2025 · Semiconductor international aspects and global trade challenges

Meeting with Raphaël Glucksmann (Member of the European Parliament, Rapporteur)

29 Oct 2024 · Foreign Investments Screening regulation

Meeting with Giorgio Gori (Member of the European Parliament) and BASF SE and The Food and Beverage Carton Alliance

25 Sept 2024 · Presentation of priorities

Meeting with Mairead McGuinness (Commissioner) and

10 Sept 2024 · High-level executive roundtable: preventing the circumvention of EU sanctions on sensitive goods.

Meeting with Valdis Dombrovskis (Executive Vice-President) and BUSINESSEUROPE and

10 Sept 2024 · Preventing the circumvention of EU sanctions on sensitive goods

Chip industry backs ECHA role but defends RoHS criteria

2 Apr 2024
Message — The association supports moving responsibilities to the European Chemicals Agency. They urge that criteria for reviewing restricted substances remain unchanged.12
Why — Staying with current criteria provides regulatory stability and avoids new compliance requirements.3

Semiconductor industry urges expansion of EU Talent Pool

31 Jan 2024
Message — The association suggests including students and trainees and expanding partnerships to countries like Taiwan. They also argue that simplified migration procedures should be mandatory.123
Why — Accessing international talent would help fill the projected shortfall of 350,000 industry workers.4

Semiconductor industry urges flexibility in new vehicle recycling rules

4 Dec 2023
Message — The association requests easier criteria for chemical exemptions and a clear process for new ones. They also argue that semiconductor plastics should be exempt from recycled content targets to ensure safety.12
Why — This would allow manufacturers to maintain high-performance standards while avoiding unfeasible recycling mandates.34
Impact — Environmental groups lose the strict regulatory hurdle requiring all criteria for hazardous material exemptions.5

ESIA urges including semiconductors as strategic net-zero technology

3 May 2023
Message — The association requests that semiconductors be added to the regulation's annex as a strategic technology. They argue chips are essential components underpinning almost all net-zero technologies and applications.12
Why — This would simplify the regulatory framework and improve the investment environment for chip manufacturers.3

ESIA urges longer deadlines and recycling in forced labour ban

30 Nov 2022
Message — ESIA requests doubling the information request timeframe to 30 working days. They suggest recycling specific components instead of disposing of entire products. The regulation should also recognize existing industry due diligence schemes.1234
Why — Focusing disposal on specific components reduces costs and prevents unnecessary waste.5
Impact — Forced labour victims could see delayed enforcement due to extended investigation timelines.6

Semiconductor group calls for uniform EU customs governance

19 Sept 2022
Message — ESIA calls for a uniform EU governance layer to eliminate fragmented national implementation and administrative burdens. They advocate for tangible benefits for trusted traders, specifically moving toward process-based mechanisms and self-clearance at borders.123
Why — Harmonized rules and simplified digital procedures would reduce costs and accelerate global supply chains.45

Response to Single Market Emergency Instrument (SMEI)

11 May 2022

The feedback by the European Semiconductor Industry Association (ESIA) can be found in the attached document.
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Response to European chips act package – Regulation

9 May 2022

ESIA welcomes the Chips for Europe Initiative. However, it ought to be emphasised that the programme is targeting European industry needs adequately. ESIA calls on the EU to focus on IP design in EU’s key verticals in automotive, industrial, telecommunication infrastructure (6G), health, personal electronics as well as smart home and energy, keeping them in mind during budget negotiations for the Chips Joint Undertaking. The Chips JU should allow for innovations across a wide range of technologies since “leading edge” varies strongly based on applications, meaning that node shrinkage should not be the only denominator for defining innovation. ESIA deems following an “R&D ecosystem” approach as consequential and proper; however, a balance between research & technology organisations, universities and industry must be ensured. R&D&I programmes should take rapid commercialisation into account. ESIA believes that fast-track and/or ad hoc funding instruments are needed to focus on a limited amount of well-defined EU priorities. The definition of “'first-of-a-kind’ in the Union” is a positive example for enabling facilities for Europe for which it today depends on other regions. This will develop the ecosystem in the EU in an accelerated manner, enhancing innovation and supply chain resilience. ESIA welcomes that the scope is not restricted to certain technologies and/or node sizes, allowing for projects serving the EU economy’s mid- and long-term demands, e.g., chips in the 40/28-12 nanometre range as well as other important technology fundamentals for the electronic systems such as memory. Pillar 3 of the EU Chips Act suggests far-reaching and unprecedented market interventions. The definition of “crisis” raises questions. It is important to understand that the current chip shortage is not caused by a crisis in chip production due to production stops of chip factories or disruptions in raw material supply. The shortage is a consequence of rising demand for chips needed during the pandemic, coupled with big fluctuations in chip demand of important sectors such as automotive and industrial. It triggered a rippling supply-demand imbalance felt across the world. The shortage, contrary to Recital (1) of the Chips Act, is not a symptom of permanent and serious structural deficiencies in the Union’s semiconductor value chain. In fact, the current shortage is a global phenomenon and cannot be solely attributed to one region’s chip ecosystem. The shortage is experienced across the world, including in regions with the largest chip manufacturing facilities.The proposed “Toolbox” measures do not reflect the complexity and uniqueness of the semiconductor supply chain, the requirements of the users (downstream) and the manifold reasons why a shortage may occur: e.g. from raw and ultra-pure materials to gas and chemicals, tools and equipment’s shortage, worldwide logistics’ outage among the FE and BE facilities, etc. The suggested, static measures – mandatory sharing of numerous market information with unclear definition and subject to sanctions, priority-rated orders, joint procurement of chips and export controls – will not be effective in preventing supply disruptions. Today, a car comprises ca. 1000, a smartphone ca. 160 different chips. Most chips are not “off-the-shelf” or “one-size-fits-all” products. Chip factories are not homogeneous and only able to manufacture a specific range of node sizes and transistor technologies. This means that Open EU Foundries and Integrated Production Facilities in the EU would only be able to manufacture and supply a very limited number of the chips required. “Just-in-time” supply chains of downstream sectors increase the risk of disruptions since they do not reflect the long lead times for chip production (4-6 months). The focus of a toolbox should shift to instruments that can effectively help chip users to enhance their security of business continuity. Therefore, Pillar 3 should be revised entirely.
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ESIA Urges Wording Correction for Mercury Lamp Exemption

12 Jul 2021
Message — ESIA asks the Commission to correct a discrepancy in the draft annex. They request the wording 'Mercury in lamps emitting light in the ultraviolet spectrum'. This ensures technical accuracy for semiconductor manufacturing where no alternatives exist.12
Why — Maintaining the exemption prevents production halts and significant costs for semiconductor manufacturers.34
Impact — Downstream sectors lose access to essential components if semiconductor production is disrupted.5

ESIA seeks correction to mercury exemption for ultraviolet lamps

12 Jul 2021
Message — ESIA asks the Commission to correct a wording error in the draft annex. They request the exemption cover all mercury lamps emitting light in the ultraviolet spectrum.12
Why — Maintaining this exemption ensures the continuity of essential European semiconductor production.34
Impact — Restricting these lamps would harm many sectors and technologies relying on semiconductors.5

Semiconductor industry warns REACH revision threatens EU digital goals

1 Jun 2021
Message — ESIA requests that chemicals used in closed manufacturing systems be excluded from authorization requirements. They advocate for simplified procedures for low-volume materials essential to semiconductor production.12
Why — This would reduce compliance burdens and prevent manufacturing disruptions for critical technology sectors.34

Meeting with Nele Eichhorn (Cabinet of Vice-President Cecilia Malmström)

4 Apr 2018 · Semiconductor industry in the EU

Meeting with Günther Oettinger (Commissioner) and BUSINESSEUROPE and

8 Sept 2016 · Dual use

Meeting with Thibaut Kleiner (Digital Economy)

27 Jun 2016 · Digital platforms, DSM, copyright