What You Need to Know About PFAS By Julia Freer, JLFG Communications
unintentionally added PFAS and to any product where substitution looks possible. The broadest restrictions will take effect between 2030 and 2032. Figure 2 presents a general timeline. As of October 2024, Maine’s bill is the only one to specifically list semiconductors as a product category exempted from the 2032 PFAS phase-out. Other states will likely follow suit before the broadest restrictions come due.
regulation is 10 parts per billion (ppb). The bill, which also restricts PFAS in consumer goods, defines a PFAS facility as “any site, area, or location where PFAS is or has been used in a manufacturing process.” The best way for a fab or other manufacturing facility to ensure they don’t run afoul of water-related PFAS regulations is not to release these chemicals into the environment. A combination of on-site filtering and recycling can accomplish this goal. Something as simple as installing activated charcoal water filters or reverse osmosis systems can stop PFAS from entering the public water system. Water testing will verify if your Even legislation that does not directly restrict the use of PFAS in semiconductor manufacturing can affect our industry if we cannot procure these chemicals. In late 2022, 3M announced its intention to exit PFAS manufacturing by 2025, and the company intends to follow through. Given 3M’s history of supplying PFOA and its $10-12 billion settlement to support remediation of PFAS in US public water supplies, the move makes sense for the company even without the demands of the Minnesota law prohibiting PFAS manufacturing. The question is how 3M’s move will affect the supply chain. Its customers will be forced to switch suppliers, perhaps outsourcing to countries without strict environmental regulations regarding disposal and wastewater treatment. Regulations restricting PFAS use in consumer goods may also affect the cost and availability of these chemicals in our industry. Suppliers threatened with lawsuits may decide to exit the market or indirectly pass the cost of legal bills to their customers. As a minor player in the global PFAS market, semiconductor companies have limited clout. For example, the semiconductor industry buys a tiny percentage of global production of several fluoropolymers that are used extensively to make all sorts of equipment. It may be especially hard to secure shipments of these materials. Do Something filtration is sufficient. Supply Chain Risk It’s a good idea to understand your company’s risk regarding PFAS. Do you know what PFAS are in your facilities? Have you contacted suppliers to learn about potential supply chain disruptions due to pending PFAS regulations? Do you know what’s in your wastewater? If you want to stay abreast of the ever-changing regulatory landscape and have a say in our industry’s response to PFAS risk, you can participate in one of SEMI’s PFAS working groups or the Semiconductor Industry Association’s PFAS Consortium. Dozens of companies in our industry are involved in discussions around supply chain resiliency, transparent communication, and transition strategy. The long-term goal is to finalize an industry roadmap for PFAS detection, replacement, and remediation, along with standardized communication to ease the burden of meeting reporting requirements.
You have probably heard about health and environmental concerns related to per- or polyfluoroalkyl substances (PFAS). Companies are being pressured to replace PFAS with safer alternatives for nonstick coatings, water- resistant fabrics, firefighting foams, and more to meet upcoming restrictions. For manufacturers, including those in the semiconductor industry, PFAS replacement is incredibly complicated. The Proliferation of PFAS PFAS are used in nearly every step of the semiconductor manufacturing process, from lithography through packaging. This isn’t merely a concern for companies making and purchasing process chemicals. The consequences of PFAS use apply to every company in the industry, whether a facility makes chemicals, materials, equipment, or components. Even companies that outsource all their manufacturing probably have PFAS in their buildings, and they should also know what their vendors are doing. Some applications of PFAS are common to multiple manufacturing sectors. Items such as tubing, fittings, cables, filters, valves, pumps, lubricants, and power supplies are relatively universal. The semiconductor industry can learn from what other sectors are doing to replace PFAS and join forces to advocate for PFAS-free supplies and components. However, what works for, say, industrial or automotive sectors might not be high enough purity to be compatible with semiconductor particle contamination limits. Other PFAS uses are industry-specific. Fluorocarbon gases are required to etch silicon. Photoacid generators (PAGs) and etchants containing PFAS enable 193mm and UV lithography. The list goes on. Research into PFAS-free alternatives is ongoing, but we are still many years away from workable substitutions that meet yield, performance, and productivity requirements. Companies should continue R&D efforts to replace PFAS and invest enough to accelerate progress. Meanwhile, there are several urgent issues that our industry needs to consider related to newly enacted and upcoming legislation about PFAS. The Regulatory Environment As legislation restricting the use of PFAS proliferates, action is becoming a matter of compliance. While most of the proposed laws banning PFAS target consumer goods, there are several issues for our industry to consider: reporting requirements, wastewater treatment, and supply chain risk. But first, let’s talk a bit about existing and pending legislation. The widespread PFAS ban that the European Chemical Agency (ECHA) proposed in early 2023 is still under discussion. SEMI and the European Semiconductor
Industry Association (ESIA) were among many industry groups that submitted feedback. They requested a 12- year derogation for the entire semiconductor industry supply chain. This is based on the critical role that our industry plays in multiple end markets and the difficulty in replacing PFAS in our manufacturing processes. The regulatory situation in the U.S. is complicated by a multitude of laws that are in effect or under consideration in over half the states. A search of legislation with the keyword “PFAS” results in over 500 entries for federal and state measures. I attempted to review legislation intending to restrict PFAS use and quickly became overwhelmed. The map in Figure 1 color-codes states according to the most extensive bill passed or under review. Some states that intend to restrict PFAS in many categories of consumer products, for example, also have laws relating to wastewater management, firefighting foam, or PFAS monitoring. (Caveat: I don’t guarantee that the map is 100% correct, but it gives an idea of the scope of PFAS legislation.)
Figure 2: Timeline of passed and pending PFAS regulations
Reporting For companies outside the consumer goods industry, the immediate need is to plan for reporting requirements from the U.S. Environmental Protection Agency (EPA) that will take effect in January 2026. Some states have separate reporting laws, but federal law may override those. According to the EPA requirements, companies will need to report on their PFAS usage dating back to 2011. Any entity that manufactures PFAS chemicals or PFAS-containing products is obligated to collect and share a multitude of data, including: • The quantities of each specific PFAS used and how it is used in the manufacturing process • Description of byproducts resulting from manufacturing, processing, or disposal • Environmental and health effects of all PFAS- containing substances or mixtures • Plans for disposal of all of the above If you don’t have a plan for generating and tracking the data, it’s time to start. Data collection will require tracking suppliers of all chemicals and components to discover whether those items contain PFAS. The EPA’s 138-page reporting instructions document contains all the details. Wastewater From a public health perspective, keeping PFAS and other toxic chemicals out of our soil, water, and air is critical. PFAS laws relating to water systems or waste treatment are also relevant to our industry because they apply to any facilities in the state regardless of what they make or what industries they serve. Discharge of PFAS- containing waste, whether accidental or not, can carry fines or get a company sued. A New Hampshire bill, which the governor signed in August 2024, exposes any PFAS facility releasing hazardous waste containing PFAS into ground or surface water to liability. The concentration that triggers the
Figure 1: U.S. Map Highlighting states with passed or pending legislation regulating PFAS use A recently passed law in Minnesota is the most far- reaching to date. It bans PFAS in eleven categories of consumer products beginning January 1, 2025, and in “any product that contains intentionally added PFAS” in 2032, with an exception for “currently unavoidable use.” Laws in several states, including California, Oregon, and New York, restrict PFAS in one or more consumer product categories as of January 2025. Other similar state restrictions will take effect in 2026. Pending laws in several states mimic the wording of the Minnesota bill. Most state-level bills aim to eventually phase out all “unavoidable” PFAS use, though they don’t clarify how they determine whether a use is unavoidable. The bills start with bans on intentionally added PFAS in specific consumer goods categories, as noted above, with provisions five to eight years out that extend to
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