Regulatory Compliance in a High Tech

Environment

Dr Mike Czerniak, Edwards, UK Environmental Solutions Business Development Manager

Contents

• RoHS

• Edwards’ Ethical Purchasing Policy

• RoHS – Restriction of certain Hazardous Substances

• EU RoHS vs. CN RoHS – Implications for Edwards

• REACH Regulation ( RoHS!)

• GHGs

• Which gases to worry about?

• Motivations to reduce PFC emissions

• COP21

• WSC 2010

• WSC 2020

• 200 mm Fab footprint

• 300mm Fab footprint

• Impact of HTFs

• Edwards’ CO2 footprint

• Summary & Conclusions

1. RoHS - Restriction of the Use of

Certain Hazardous Substances ( RoHS )

in Electrical and Electronic Equipment (

EEE ) Directive (2011/65/ EU )

3

Edwards Ethical Purchasing Policy

Adherence to Edwards’ ethical purchasing policy and Code of Conduct is a condition to doing business with Edwards.

Edwards selects and purchases goods and services which:

• Are safe.

• Are environmentally responsible.

• Are produced and delivered under fair labour conditions.

• Are fair value for the price, quality and volume offered.

• Meet government, industry and Edwards’ safety and quality standards.

• Do not involve any bribery, corruption or ‘facilitation payments’

Edwards will seek alternative sources where the conduct of suppliers violates Edwards’ global Code of Conduct or Ethical Purchasing Policy, and where there is no effort by the supplier to address that situation within an agreed time period.

EU RoHS – Restriction of certain Hazardous Substances

• Aims to reduce hazardous material going to landfill • Applies to specific categories of electrical equipment

• Initial focus on high volume disposable products, mainly consumer • From July 2019 includes all electrical & electronic equipment unless Exempt • SEMI instrumental in maintaining Exemption for Large Scale Industrial Tools

• Controls hazardous materials to a defined threshold limit • Lead, Mercury, Hexavalent Chromium, Cadmium, 2 Poly-brominated flame

retardants (PBB’s and PBDE’s) • EU will include 4 phthalates (DEHP, BBP, DBP, DIBP) from 2019#

# medical and control equipment categories have until 2021

• 0.1% by weight (0.01 for cadmium) in each ‘homogeneous material’* *A material which can be mechanically separated - by grinding, cutting etc. e.g. the leg of a resistor; a surface coating

• Many national versions of RoHS (and symbols)! • Significant variation in scope, marking and documentation requirements • EU and China RoHS impact Edwards’ products

• Substantial customer demand to eliminate these materials

EU RoHS vs. CN RoHS – Implications for Edwards

• EU RoHS – • Requires the ‘RoHS substances’ to be eliminated unless covered by a Material Exemption

• Exemptions typically valid for 5-7 years but need technical justification, e.g. no viable alternatives exist • Gets harder to justify extending exemptions – overhead-intensive – forcing development!

• CE mark applies under RoHS2 • Edwards product sold into medical applications in scope since 2015

• Instrumentation in scope from 2017, all other non exempt electrical from 2019

• China RoHS – • Requires labelling and a materials declaration in the manual, i.e. “reporting” • All Edwards product in scope, including powered accessories

• Edwards ‘voluntary’ RoHS Policy • Virtually all product already EU RoHS compliant, standard requirement for new designs. • Compliance based on supplier declarations and tests in line with EN50581 • EU RoHS compliance systems significant in supporting rapid response to China RoHS2

• Supplier Impact • Supplier Approval and Sample Approval processes require RoHS compliance • RoHS substance information recorded in core manufacturing systems at component level • New or re-sourced components require RoHS Declaration • Controlled by product Sample Approval and evidence maintained.

RoHS timeline

Feb 2003

• 2002/95/EC adopted: Restriction of Hazardous Substances Directives

• Restricts 4 heavy metals (lead, mercury, hexavalent chromium) and 2 flame retardants (PBB & PBDE)

• Applies to 8 of 10 equipment categories defined by the WEEE Directive 2002/96/EC, Annex IA

• Excludes large scale stationary tools or fixed installations

Aug 2004

• Transposition into National Law

July 2006:

• Entry into force

June 2011

• Directive 2011/65/EU RoHS (recast) 2

• Compliance Mandatory for CE marking (where in scope)

• Similar evidentiary requirements to other CE mark Directives.

• Scope expanded, new Category 11: Other EEE not already covered

• Spare parts, cables no longer out of scope unless reusing spares exempt under RoHS 1 and customer informed

• Majority of excluded Product Categories to come into scope (arge scale stationary/fixed equipment remains out of scope)

Jan 2013

• RoHS compliance (where in scope) mandatory for CE in addition to any other Directive which may apply (eg Machinery, EMC, LV, Medical Device) RoHS

July 2014:

• Now in scope

• Medical Devices

• Monitoring and Control Instruments

Mar 2015

• Secondary Legislation: Commission Delegated Directive (EU) 2015/863 amending Annex II – restricted substances DEHP, BBP, DBP & DIBP

• Products out of scope of new substance restrictions:

• Toys (covered by tighter dedicated legislation)

• cables or spare parts for repair, reuse, updating or upgrading EEE on the market pre July 2019

• medical devices, in-vitro medical devices, monitoring & control instruments, industrial monitoring and control instruments on the market pre July 2021.

July 2016

• Now in scope:

• In-vitro Diagnostic Medical Devices

July 2017

• Coming into scope:

• Industrial Monitoring and Control Instruments

July 2019

• Coming into scope:

• Electrical and Electronic equipment not covered by other Categories

• New phthalate Material Restrictions DEHP, BBP, DBP and DIBP restrictions come into force on:

• Large and small household appliances.

• IT and telecoms equipment.

• Consumer equipment.

• Lighting equipment.

• Electrical and electronic tools.

• Leisure and sports equipment.

• Automatic dispensers.

• EEE not covered by any other category

July 2021

• DEHP, BBP, DBP and DIBP restrictions come into force on:

• medical devices

• In-vitro medical devices

• monitoring and control instruments

• industrial monitoring and control instruments

REACH Regulation ( RoHS!)

• New EU law on Registration, Evaluation and Authorisation of Chemicals

• Applies to all substances sold into the EU • pure and mixtures

• liquid and gaseous chemicals, metals, alloys etc

• few exclusions (e.g. untreated natural materials such as limestone)

• It is illegal to make or import

• > 1 tonne p.a. of any substance within the EU

• Unless it has been ‘pre-registered’ with the EU chemicals agency

• Must notify customers and EU of any articles

• Containing certain ‘Substances of Very High Concern’ (SVHC) • carcinogens, mutagens, teratogens (CMTs) & persistent, bio-accumulative toxics (PBTs)

• EU SVHC list updated twice a year

• to > 0.1% by weight of the Article

• ‘REACH-like’ regulations in many of our other major markets

• Ensure Edwards is not an importer of substances for REACH

2. GreenHouse Gases (GHGs)

Gases that contribute to atmospheric climate change

because of their high Global Warming Potentials (GWP)

Which gases to worry about?

• GWP = Global Warming Potential • CO2 = 1 • N2O = 298 over 100 years • SF6 = 23,900 over 100 years • CF4 = 7,300 over 100 years but

has an atmospheric lifetime of 50,000 years!

• SF6 & CF4 are PFCs = Per Fluorinated Compounds

Getting lunch, 48,000 BC

CF4: David Speed’s paper @ SESHA 2016 Co-authored by B Raley & L Beu My additions in red

Motivations to reduce PFC emissions

• CO2 is the primary gas responsible for climate change

• There is an industry drive to reduce PFC emissions due to their high GWPs (>>CO2) • Included in ITRS/IRDS roadmap • WSC targets • COP21

• Green Labelling is starting to be introduced • Many chip manufacturers are auditing

fab emissions per product

• Reducing power and/or fuel consumption reduces CO2 emissions: 1 kWh ≈ 500g CO2

COP 21 (Conference of the Parties)

• Is was the 21st meeting on Climate Change under the auspices of the United Nations to make policies following reports from the IPCC (Inter-governmental Panel on Climate Change)

• As a result, delegates signed-up to implement changes that would reduce carbon emissions to levels that would limit the global atmospheric temperature rise to 2.7oC by 2100

• N.B. The Met Office, the UK’s official office of meteorology, recently announced that 2015 would be the first year in which the average global temperature exceeded the average temperature for preindustrial years by 1oC

WSC 2010 PFC targets

• 1990’s – PFCs recognised as GHGs contributing to climate change

• 1995 – Du Pont threat to restrict C2F6 unless 80% utilization

• 1999 – WSC voluntary target to limit PFC emissions to 90% of 1995 levels by 2010 (some local variations) • Significant reduction given the CAGR of the

semiconductor industry!

• 2010 – SIA, ESIA, KSIA & JSIA able to report having beaten target! • Largely achieved by the replacement of PFC

CVD chamber clean gases like CF4 & C2F6 by NF3 which is efficiently consumed by the process tool & use of gas abatement

WSC 2010 Achieved

http://www.semiconductorcouncil.org/wsc/uploads/seoul_2010.pdf

http://www.semiconductorcouncil.org/wsc/uploads/WSC-2011.pdf

WSC PFC 2020 target

• In 2011, the following targets were agreed by the WSC:

The implementation of best practices for new semiconductor fabs. The industry expects that the implementation of best practices will result in a Normalized Emission Rate (NER) in 2020 of 0.22 kgCO2e/cm2, equivalent to a 30% NER reduction from 2010 aggregated baseline. Best practices will be continuously reviewed and updated by the WSC.

• http://www.semiconductors.org/clientuploads/directory/DocumentSIA/International%20Trade%20and%20IP/May2014JOINTSTATEMENTTaipei18thWSC%20Final.pdf

• http://www.semiconductorcouncil.org/wsc/

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Impact of exhaust abatement

300mm 10,000 wspm Fab PFC footprint PFC chamber cleans

Impact of Heat Transfer Fluids (HTFs)

• These are typically PFC liquids and can have fairly high GWPs (previously treated as zero)

• The US EPA now include these in a fab’s GHG inventory • Typically has the effect of increasing the PFC inventory

by ~10% for a 300mm fab • This increases the challenge of meeting WSC 2020

targets • Also highlights the importance of abating PFC

emissions from etch processes in 300mm fabs

Edwards’ Corporate Carbon Footprint

Summary &

Conclusions

Summary & Conclusions

• RoHS 2.0 is part of CE & from 2019 will include plasticisers • Climate Change concerns put pressure on industry to reduce

GHG emissions • The industry has responded by the WSC setting voluntary targets

bases on normalised emissions per cm2

• Replacing PFC CVD chamber cleaning gases with NF3 has helped • Including PFC-based HTFs has made things more challenging • Abating etch gas emissions will become increasingly important • The good news: this is all doable!

• Take-away thought……

To put it the IKEA way…