European Semiconductor Industry Association

The European Semiconductor Industry Association (ESIA), representing the European leadership in semiconductor research, design, and manufacturing, would like to make recommendations regarding the finalisation of the implementing act laying out the format. Semiconductors (or chips) are at the core of Europes clean and digital transitions.

The European Semiconductor Industry Association (ESIA), representing the European leader-ship in semiconductor research, design, and manufacturing, would like to comment on the po-tential impact of the upcoming Circular Economy Act and the revision of the Waste Electrical and Electronic Equipment (WEEE) Directive on the sector. Semiconductors are the core of Europes clean and digital transitions.

European Semiconductor Industry Association ESIA Position Paper on the CS3D Input to the Commission Proposal for a Directive on Corporate Sustainability Due Diligence Brussels, 23 May 2022 ESIA represents the European semiconductor sector which is operating and competing in Europe and globally.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

ESIA supports a stronger role for ENISA in developing and maintaining EU cybersecurity certification schemes, provided processes remain transparent, technically driven, and closely aligned with industry realities. Global standards and interoperability must remain central to avoid market fragmentation.

A holistic, coherent policy strategy and regulatory approach across all policy areas is needed to boost the EUs semiconductor industry. Semiconductors are a pervasive technology, key components of everyday electronics devices that make life easier, safer, more secure, and greener. Semiconductors are a common denominator for archieving European ambitions across the board, from the green to digital transitions.

The European Semiconductor Industry Association (ESIA) welcomes the Net Zero Industry Act and its goal to simplify the regulatory framework and improve the investment environment for net-zero technologies. ESIA fully supports the transition to a climate neutral, clean economy, and the corresponding redesign of the EUs energy system.

ESIA represents the European semiconductor sector where companies are operating and competing in Europe and globally. The landscape of the REACH regulation and the uncertainty it brings to their manufacturing process in Europe compared with other regions of semiconductor production is one critical area of consideration under a targetted revision of REACH.

The European Semiconductor Industry Association (ESIA), representing the European leadership in semiconductor research, design, and manufacturing, welcomes the opportunity to provide feedback on the upcoming implementing and delegated acts under Article 7(8), (9) and (10) of Regulation (EU) 2025/40 concerning recycled plastic content, recycling technologies, and recycled content originating from third countries.

The upcoming Advanced Materials Act is critically important for the European semiconductor industry. Next-generation chips will be defined as much by materials innovation as by lithography or design: new transistor architectures and scaling pathways require novel high-purity materials, new deposition/etch chemistries, improved dielectrics and conductors as well as advanced packaging materials for high-density…

The European Semiconductor Industry Association, ESIA, calls on policy-makers to support the use electronic components, including microelectronic sensors, for advanced particle detection and contamination analysis. Likewise, the use of ICT-enabled (including AI-enabled) solutions for water management should be encouraged.

ESIA is a cosignatory of the submission of the RoHS Umbrella Project. In addition, ESIA would like to express its supports for the allocation of responsibilities to the European Chemicals Agency. However, ESIA appreciates the criteria for review and amendment of the list of restricted substances as it is currently set out in Article 6 and would recommend not changing these criteria.

Executive Summary Semiconductors are key components of everyday electronic devices that make life easier, safer, more secure, and greener. From ground and air transportation to pass-ports, payment cards, terminals, servers in data centres, desktop computers, sensors, etc., semiconductors are ubiquitous, fulfilling a crucial role in the whole domain of the Cyber Resilience Act (CRA).

Following internal membership surveys conducted by ESIA (European Semiconductor Industry Association) and SEMI Europe, several suppliers of semiconductor manufacturing equipment confirmed that there are components containing MCCPs in their products. These suppliers reported that the substances are intentionally used in some semiconductor equipment, not only present as traces.

ESIA welcomes the Chips for Europe Initiative. However, it ought to be emphasised that the programme is targeting European industry needs adequately. ESIA calls on the EU to focus on IP design in EU’s key verticals in automotive, industrial, telecommunication infrastructure (6G), health, personal electronics as well as smart home and energy, keeping them in mind during budget negotiations for the Chips Joint…

Semiconductor companies operate in a global supply & manufacturing chain and worldwide markets, as such are heavily involved in international trade. Simple, clear and business-friendly international trade rules are critical to their competitiveness.The principle of the "last substantial transformation" as defined by WTO is suitable for determining non-preferential origin without requiring complex calculations.

Following internal membership surveys conducted by ESIA (European Semiconductor Industry Association) and SEMI Europe, several suppliers of semiconductor manufacturing equipment confirmed that there are components containing LC-PFCAs in their products.