SEMI Europe
SEMI
SEMI is the industry association representing 2000+ companies to advance the technology of electronics manufacturing.
ID: 402302029423-14
Lobbying Activity
Response to Review: Restriction of the use of hazardous substances in electronics
14 Mar 2022
We support the RoHS Directive essentially as it stands with supporting information from FAQs and other ‘soft’ measures. However, we do think several aspects of the exemption process would be improved with a few changes, particularly relating to aspects of timing.
The RoHS Directive should remain as *lex specialis* for EEE, and EEE related restrictions in other regulations should be transferred to RoHS. We would not like to see substance restriction and exemption assessments entrusted to an EU agency. Some small adjustments would be beneficial in the provisions for spare parts. We think the scope of the Directive is sufficiently clear and additional provisions related to recycled material and critical raw materials should not be introduced. If new or revised provisions on enforcement and market surveillance are introduced, we ask that relevant distinctions be made between waste streams from professional industrial activities and waste streams from consumer and other sources (the former of which are more robustly constrained by other considerations). We think the transformation of the RoHS Directive into a regulation would, generally speaking, be a good idea. We do *not* think that RoHS should be repealed (with the criteria then being covered by REACH or EEE waste and sustainable product legislation). Indeed, we would favor moving all EEE related substance restrictions into RoHS, in part because the “RoHS” acronym now has such global recognition and duplication.
Read full responseMeeting with Thierry Breton (Commissioner) and
5 Oct 2020 · Roundtable skills on Microelectronics
Meeting with Nicolas Schmit (Commissioner) and
5 Oct 2020 · Pact for Skills Roundtable with the microelectronic sector.
Response to Persistent organic pollutants - annex I amendment
29 Sept 2020
SEMI Europe welcomes the opportunity to provide feedback to the proposed amendment and is pleased by the additional review of the PFOA restriction with a view to addressing practical matters of implementation and enforcement of the restriction. Please find attached our feedback. We would welcome the opportunity to discuss our recommendations with the European Commission.
Read full response25 May 2020
SEMI Europe welcomes the opportunity to provide its feedback on “Amendment of Annex XVII REACH and its Appendices regarding CMRs, liquid substances or mixtures and testing methods.” Please find attached our detailed feedback on this matter.
Read full response4 Dec 2019
SEMI welcomes the opportunity to provide comments into the consultation on legislation to add PFOA and related substances as a restriction under the EU POPs regulation. Please find attached our feedback.
Read full responseResponse to Revision of the Machinery Directive
8 Feb 2019
SEMI, the association representing the global electronics manufacturing industry, welcomes the opportunity to comment on the revision of the Machinery Directive.
AI technologies are already used in semiconductor manufacturing:
Using artificial intelligence (AI) tools, today’s semiconductor fabs combine equipment know-how and manufacturing statistics to manage massive fault detection data, increase manufacturing efficiency and improve yields. For instance, AI enables the real-time collection and monitoring of massive amounts of data, then alerts system administrators of any hardware failures or abnormalities. AI also makes it possible to automate manufacturing process adjustments and corrections by providing feedback that can drive higher processing efficiency. A secure cyber-physical space is critical to ensure the safe use of industrial data, AI, and, by extension, fab equipment, making security a top priority for electronics manufacturers. However, the consensus view of SEMI members is that addressing these security concerns through any revision on the Machinery Directive would be difficult and problematic. The Directive establishes essential health and safety requirements manufacturers must meet before placing its products on market with the flexibility of using specific state-of the-art technologies. SEMI’s position is that the use of AI technologies and its impact on cybersecurity is better discussed and framed under relevant cybersecurity policies.
Customers increasingly demand digital documentation:
In electronics manufacturing, there is a general shift to eliminate the use of paper for technical and operational reasons. For instance, customers demand that documents accompanying products are in digital format, as paper is generally prohibited in clean rooms. Many businesses also use software tools, mainly in English as the common business language, that update customers on revisions to product manuals. This includes training programs delivered via software for operators on the use and maintenance of products. Therefore, adapting the Directive’s requirements for documentation by allowing digital format with linguistic flexibility would reduce administrative burden for the industry.
Alignment with the New Legislative Framework will be necessary:
While it has not been a serious concern for businesses, the Machinery Directive should align with the New Legislative Framework, and adapt the relevant documents, such as declaration of conformity, technical file, instructions etc. For instance, SEMI members report that they receive requests to include an Annex IIB for partly completed machinery, and the use of this Annex may require clarification on when it is necessary to provide it. As to enforcement, market surveillance authorities should be better coordinated, as many businesses report that market enforcement varies from one Member State to another and in some cases is too lax, posing environmental, health and safety risks to users.
Practical guidance would be helpful to remove legal unclarities of implementation the Machinery Directive:
While some manufacturers report possible legal uncertainties surrounding the implementation of the Machinery Directive (e.g. partly completed machinery) and suspect inconsistencies and overlaps with other directives (e.g. with the Low Voltage Directive), many SEMI members do not see these as serious concerns and reasons to revise the Machinery Directive. Rather, SEMI members prefer specific guidance as to when to refer to the Machinery and e.g. Low Voltage Directives.
SEMI members’ common view is that the Machinery Directive is in general fit for the purpose, provides essential health and safety principles, and eases the circulation of machinery both in the EU and beyond. However, the improvements proposed here would be beneficial for all.
Read full responseResponse to Restriction of hazardous substances - evaluation
11 Oct 2018
SEMI, representing the electronics manufacturing industry, welcomes the opportunity to give feedback on the roadmap. We see the following areas of improvement: i) RoHS and REACH inconsistencies; ii) global aspect of RoHS; iii) retention of Large-Scale Stationary Industrial Tools (LSSIT) and Large-Scale Fixed Installations (LSFI) exclusions, and importation of used equipment; and iv) the issues surrounding components:
• There exist serious inconsistencies between RoHS and REACH, e.g. different product information requirements, contradicting restrictions for certain substances, inconsistent ways of calculating action threshold concentrations, and it is not clear why certain material restrictions have been included in REACH but not into RoHS (ex: PFOA). Having to ensure compliance of EEE to both RoHS and REACH is damaging for manufacturers with complex and global supply chains.
• Several adaptations of RoHS-like laws in third countries are not realized with the same detailed requirements of RoHS. Exemptions by certain RoHS-like laws are not harmonized with RoHS, and as far as one can tell they do not expire. The basic facts about other laws in third countries should be considered by the EU in the hopes that more harmony could be built into RoHS.
• Of very high importance to our industry is the retention of the LSSIT and LSFI exclusions from RoHS scope. The justifications for their exclusion from the first two versions of RoHS are equally valid today. While some equipment categories are no longer excluded, retention of the LSSIT and LSFI exclusion allows continued importation of most used equipment, that is vital to manufacturing of semiconductors in Europe.
• Piece of used equipment is economically beneficial and environmentally sound to extend the useful life of equipment as long as possible. Importing a used equipment is a first placing on the EU market and there is an obligation to confirm the compliance of the equipment to RoHS. Yet, it is most likely that neither the importer nor the non-EU seller of the used equipment (who is not necessarily the OEM) can get access to the necessary component information for reasons including: neither the seller nor importer has access to original OEM design information; new research of the components cannot be done as they are not marked with complete origin information; and the OEMs are non-responsive/no longer in business. Thus, RoHS is not currently supportive of importing used equipment into the EU whereas used equipment already on the EU market may be sold and resold without any burdens of RoHS. Many businesses in Europe rely upon imported used equipment and if adjustments are not made in RoHS, this will eventually hamper Europe’s competitiveness and jeopardize its industrial policy goals.
• Although components themselves do not have to be RoHS compliant, they have to be RoHS compliant for the sake of the equipment into which they are assembled. Requesting a RoHS compliance declaration is one of the most common ways supply chains answer this requirement. However, RoHS compliance can depend on one or more exemptions, all of which eventually expire, such that a component that is compliant today in a warehouse might not be compliant next year. To address this, supply chain actors have to invent a variety of additional requirements to gather necessary information about the use of exemptions for a given component. The way forward with significant benefits is to require the RoHS declaration of compliance to include a listing of exemptions relied upon to achieve RoHS compliance. This could standardize communications and reduce costs in component supply chains. Therefore, it is recommended that the DoC criteria given in RoHS Annex VI be amended to include an additional element to the effect of “Where applicable, references to the relevant exemptions given in Annex III and Annex IV on which conformity depends.”
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