SEMI Preparing Feedback to U.S. Congress on New RoHS Legislation (June 2009)


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SEMI Preparing Feedback to U.S. Congress on New RoHS Legislation (June 2009)

Overview

Last month, a bill entitled, ‘‘Environmental Design of Electrical Equipment (EDEE) Act’’ was introduced into the U.S. Congress (specifically the House of Representatives Committee on Energy and Commerce). The draft legislation is located here.

The current legislation reads:

"Except for those electroindustry products and product categories set forth in paragraph (3), no electroindustry product shall be manufactured after July 1, 2010, that contains a concentration value greater than 0.1 percent by weight of lead, mercury, hexavalent chromium, polybrominated biphenyls (PBB), and polybrominated diphenyl ethers (PBDE) as measured in any homogeneous material contained in the electroindustry product, or a concentration value greater than 0.01 percent of cadmium as measured in any homogeneous material contained in the electroindustry product."

U.S. RoHS, Restrictions of Hazardous Substances

Industry analysts have already started to refer to the legislation as U.S. RoHS as it Restricts the use of Hazardous Substances. Similar RoHS legislation has existed in Europe, China, and Korea for several years.

Possible Impacts to Equipment Suppliers

Some SEMI members are concerned about how semiconductor manufacturing equipment would likely be treated under the legislation. In the current language, there appears to be an exemption for "products or equipment used in fixed installations". The text includes the following language:

"For purposes of this subsection, ‘fixed installation’ means a combination of equipment, systems, finished products and/or components, not including lighting equipment that encompasses lighting fixtures and lamps, assembled and/or erected by an assembler/installer at a given place to operate together in an expected environment to perform a specific task, but not intended to be placed in commerce as a single functional or commercial unit."

Whether this language can be interpreted to include semiconductor manufacturing equipment is not known. The language of the exemption is different than the LSIT (Large Scale Stationary Industry Tool) exemption currently contained under EU RoHS.

Possible Impacts to Chemicals Suppliers

Other SEMI members are concerned about the scope of process chemicals in relation to the finish product. Under EU RoHS, the substance ban is interpreted in the context of the final product and not to substances used in the production of the product. Whether this analogy carries over to the proposed US RoHS legislation is not known.

SEMI Activities for U.S. RoHS

Due to the uncertainties, SEMI is currently seeking clarification from members of the U.S. Congress as to their intentions. If necessary, SEMI will advocate for changes to the legislation. These efforts are being carried out under the direction of the SEMI RoHS Working Group (WG). Membership in the SEMI RoHS WG is open to all SEMI members. If you would like to join the WG in the advocacy efforts, please contact Sanjay Baliga (SEMI Senior Manager in San Jose).