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March 1, 2023

EU Climate Law and EU Chips Act: The Potential Impact of Proposed F-Gas Regulation on Europe’s Semiconductor Industry Growth Strategy

On April 5, 2022, the European Commission presented a proposal to regulate fluorinated greenhouse gases. The proposal is amongst the last in the Fit for 55 package, aset of recommendations to revise and update the European Union (EU) legislation and to implement new initiatives aimed at ensuring that EU policies align with climate goals agreed to by the European Council and the European Parliament.

The European Climate Law enshrines the goal set out in the European Green Deal for Europe’s economy to become climate-neutral by 2050, and establishes an intermediate target of reducing net greenhouse gas emissions by at least 55% by 2030. Striving to build a green future in line with the European Green Deal, the semiconductor industry places environmental sustainability as the highest priority, while developing innovative components and systems to support critical industries such as automotive, medical, aerospace, defense and energy.

ImageThe European Chips Act recognizes the strategic importance of the semiconductor industry to ensure the digital prosperity and security of the supply chain, thus strengthening Europe’s technological competitiveness. I spoke with the SEMI Europe Advocacy team about Europe’s next steps to deliver sustainable technology solutions to resolve the region’s most pressing issues and advance the region’s environmental stewardship.

Brischetto: The European Commission reviewed the current F-gas regulation and proposed a revised version. What are F-gases?

SEMI Europe Advocacy: Fluorinated greenhouse gases (F-gases) are a family of human-made chemicals used in a range of everyday products as well as industrial applications. F-gases are used in several types of products and appliances, chiefly as substitutes for ozone-depleting substances such as chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs) and halons, which are being phased out under the Montreal Protocol and the EU legislation. For example:

  • Hydrofluorocarbons (HFCs) are used in various sectors and applications, such as refrigerants in refrigeration, air-conditioning and heat pump equipment; as blowing agents for foams; as solvents; and in fire extinguishers and aerosols.
  • Perfluorocarbons (PFCs) are typically used in the electronics sector (for example, for plasma cleaning of silicon wafers), as well as in the cosmetic and pharmaceutical industries.
  • Sulphur hexafluoride (SF6) is used mainly as an insulating gas, in high-voltage switchgear and in the production of magnesium and aluminum.

Brischetto: Why do semiconductor manufacturers use F-gases?

SEMI Europe Advocacy: Semiconductor manufacturers use F-gases for etching intricate circuitry features on silicon wafers and for cleaning chemical vapor deposition (CVD) tool chambers. The gases are energized and dissociated in plasmas to provide reactive fluorine atoms in the manufacturing tool chambers. For plasma etching, the free fluorine atoms selectively react with and remove insulating and/or conductive materials from the exposed surface of a silicon wafer to create the circuitry patterns found on modern semiconductors. In CVD tool chamber cleaning applications, the fluorine atoms react with and remove excess materials from the surface of the tool chambers themselves.

ImageSemiconductor manufacturers also use fluorinated heat transfer fluids and nitrous oxide used to cool process equipment, control temperature during device testing, and clean substrate surfaces and other parts, as well as for soldering. Nitrous oxide is used for CVD and other manufacturing processes, such as chamber cleaning.

Additional applications include refrigeration systems, commonly referred to as process chillers, and air conditioning systems used for controlling the temperature of equipment and process chambers.

Brischetto: Why are the regulations emanated by European authorities critical for environmental sustainability?

SEMI Europe Advocacy: The F-gas regulation has achieved critical success in reducing the damaging effect of high Global Warming Potential (GWP) HFC gases entering the earth’s atmosphere. SEMI members fully support European commitments to the Kigali amendment to the Montreal Protocol to achieve the legally binding Greenhouse gas (GHG) reduction targets set by the 2021 European Climate Law [Regulation (EU) 2021/1119)]. Many companies have implemented emission-reduction strategies to optimize production processes and switch to alternative input gases.

Brischetto: How is the European Commission assessing the regulations?

SEMI Europe Advocacy: The European Commission’s impact assessment reviews a variety of policy options and balances the commitment to the GHG reduction targets with the needs of the European industry to remain competitive, demonstrating that policies can deliver the required GHG reduction targets. However, the proposals from the Environment, Public Health and Food Safety (ENVI) committee incorporate additional measures that might lead to marginal improvements in emissions yet have a substantial impact on the European semiconductor industry.

Brischetto: Are these regulations affecting the goals underlined by the EU Chips Act?

ImageSEMI Europe Advocacy: Europe should assert itself as a region of excellence and ambition, ensuring that sector-critical initiatives, such as the proposed amendment of the F-gas regulation, do not adversely impact the effective operation and production efficiency of existing and new semiconductor manufacturing facilities. In the context of the EU Chips Act, the revised F-gas regulation should ensure that semiconductor industry companies, including critical equipment suppliers, are operating within a forward-looking regulatory environment to support European semiconductor ecosystem growth rather than impede the industry’s ability to grow.

Brischetto: What is the SEMI Europe advocacy team planning to do to help mitigate the risks mentioned above?

SEMI Europe Advocacy: To support Europe’s industrial growth, SEMI Europe published a position paper with key recommendations on the proposed amendment. The recommendations focus on six areas aimed at supporting the industrial green transition and Europe’s semiconductor industry growth. The position paper is also endorsed by SEMI Europe Advisory Board executives, with the goal of ensuring that Europe’s semiconductor industry remains at the forefront of Europe’s green and digital transition.

Brischetto: What are the six pillars outlined in the position paper?

SEMI Europe Advocacy: The six areas of concern presented in the paper include:

  1. Definitions for refrigeration and air conditioning systems
  2. Definitions of Fluorinated F-gas in relation to mixtures
  3. Servicing and maintenance restrictions on equipment using F-gas that will prematurely obsolete semiconductor manufacturing equipment
  4. Market prohibitions that are not technically feasible within the stated time frame impacting the ability to manufacture semiconductors in the European Union
  5. Semiconductor quota exemption that may result in uncertainty for supply of critical process chemicals
  6. Supply of high GWP F-gas for low-temperature refrigeration systems used in semiconductor dry etch applications

To learn more, review the position paper.

Thanks to the SEMI Europe advocacy team and the SEMI Greenhouse Gas Working Group for their contributions to this interview.

Learn more about Europe advocacy and SEMI Environmental Health and Safety (EHS) initiatives.

External resources

SEMI Europe contacts

Serena Brischetto is director of Marketing and Digital Engagement at SEMI Europe.