Semiconductor Equipment

Where RoHS, REACH and PFAS intersect

06 June 2024
Forever chemicals are under strict regulation in the electronics industry through two major regulations—RoHS Directive and the REACH Directive, both which started in the EU but moved to other developed countries. Source: Colored Lights/Adobe Stock

In all modern markets, ranging from North America to China, industry consortia and governments have come together to enact environmental regulations that place restrictions on suppliers, importers and sellers of commercial products. In the electronics industry, the two major regulations are the RoHS Directive and the REACH Directive, both of which originate as EU directives governing the use, import and sale of substances known to be hazardous to the environment and human health. These two EU directives have their analogues in the US, China and other developed countries.

Now that there has been widespread acknowledgement of the effects of persistent chemicals on human health, another class of compounds is coming under regulatory scrutiny. These compounds are PFAS, or per-/poly- fluoroalkyl substances.

These compounds are also known colloquially as “forever chemicals” due to their lack of natural degradation pathways and thus their persistence in the environment. As these new regulations are rolled out, materials suppliers and manufacturers can expect a few possible outcomes:

  • Maximum allowed concentrations of PFAS, like REACH/RoHS
  • Reporting requirements for certain substances classified as PFAS
  • Incorporation of PFAS into existing regulations, i.e., into REACH
  • Outright bans of PFAS, such as is being considered in the EU
  • Exemptions on any of the above, such as already occurs in aerospace under RoHS

Environmental regulations today

The European Union directive known as restriction of hazardous substances (RoHS) restricts the use of hazardous substances in electrical and electronic equipment (EEE) to reduce environmental and health risks during disposal and recycling. The current version, RoHS 3 or RoHS Directive 2015/863, targets specific heavy metals, phthalates and phenyls.

Manufacturers, importers and distributors of EEE must adhere to these regulations in order to be considered compliant with EU environmental regulations. Other nations have their own versions of RoHS (for example, China RoHS); the United States does not have a federal RoHS regulation, but certain states have RoHS regulations that overlap with the EU directive. The table below outlines the main substances covered in the EU RoHS.

Unlike RoHS, registration, evaluation, authorization and restriction of chemicals (REACH) applies beyond EEE and covers chemicals at the product level across industries. REACH includes a list of Substances of Very High Concern (SVHCs), the production, export/import and sale of which are regulated by EU authorities. It’s possible a RoHS-compliant electronic device is not REACH compliant, and vice versa, and yet certain products could be obligated to comply with both standards.

Manufacturers, importers and downstream users of chemicals are obligated to communicate information about the presence of SVHCs in products throughout the supply chain. For example, semiconductor manufacturers will provide REACH compliance statements that illustrate the expected levels of SVHCs in their products. These reports can be used by a downstream user as needed to prove their compliance should a regulator or member of the public request it.

The current version, RoHS 3 or RoHS Directive 2015/863, targets specific heavy metals, phthalates, and phenyls. Source: Sanjeev Kumar Misra/Adobe StockThe current version, RoHS 3 or RoHS Directive 2015/863, targets specific heavy metals, phthalates, and phenyls. Source: Sanjeev Kumar Misra/Adobe Stock

How PFAS plays into electronics regulations

PFAS play an important role in many products beyond electronics, but the electronics industry will eventually need to work to accommodate these regulations. Whether the new requirements involve mandatory reporting, or an outright ban, producers and downstream users of the following items are likely to be affected:

  • Cleaning materials
  • PCB dielectrics (cores and prepregs)
  • Some adhesives and sealants
  • Some thin films
  • Wiring materials
  • Battery materials

In semiconductor manufacturing, there are many other products, materials and processes where PFAS can be found, such as:

  • Etching solutions
  • Rinsing solutions
  • Antireflective coatings
  • Vapor phase soldering
  • Wafer thinning
  • Developer solutions

Today, industry advocacy groups are working with manufacturers to gather information on their usage of PFAS with the goal of providing effective guidance on regulatory action. In addition, some product groups may deserve an exemption from PFAS restrictions, such as we see in aerospace and defense with the RoHS lead-free directive.

In the U.S.: TSCA

The U.S. Environmental Protection Agency (EPA) manages the toxic substances control act (TSCA) Chemical Substance Inventory, which contains all existing chemical substances imported, manufactured or processed in the U.S. that do not qualify for an exemption/exclusion under TSCA. On October 11, 2023, the EPA published a new rule under the TSCA regarding the reporting and tracking of perfluoroalkyl and polyfluoroalkyl substances.

The new recordkeeping/reporting rule demands information regarding each PFAS compound they used or manufactured, such as:

  • Which PFAS were used and their composition
  • Any known environmental and health effects of the chemical in question
  • Amount of the substance manufactured or processed
  • Maximum measured concentration of the compound within a product
  • Descriptions of any byproducts and the disposal methods used
  • Details on any worker exposure to the PFAS in question

This new rule may apply to companies that have manufactured, imported or otherwise used PFAS for a commercial purpose at any time since the beginning of 2011. In particular, for semiconductor manufacturers and electronics manufacturing services, this rule covers PFAS usage in all of the areas mentioned in the previous section.

As new regulations are rolled out or existing regulations incorporate PFAS requirements, these data will be made available to buyers directly from semiconductor vendors or via distributors. It’s up to electronics OEMs, contract design teams, materials manufacturers and SCM platforms to understand what level of reporting they might require for their products to ensure compliance.

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