SEMI Europe

SEMI Europe welcomes the opportunity to provide feedback on the draft Implementing Regulation establishing rules on national registers of producers under the Packaging and Packaging Waste Regulation (PPWR). SEMI Europe supports the Commission's objective of improving harmonisation, reducing administrative burdens, and facilitating compliance through common registration and reporting requirements.

SEMI Europe, the global industry association representing more than 2,500 companies and 1,3 million professionals from across the global electronics manufacturing and design supply chain welcomes the opportunity to comment on the European Commissions upcoming initiative on critical raw materials.

SEMI Europe welcomes the European Commission’s “Proposal for Regulation laying down harmonized rules on Artificial Intelligence” and appreciates the opportunity to provide its feedback on this crucial matter for Europe’s microelectronics industry.

SEMI Europe welcomes the opportunity to provide its feedback on the intended revision of the CLP Regulation. The CLP revision policy options appear to be well aligned with the overall concerns identified in the Inception Impact Assessment. However, the proposal to include additional hazard information on labels for products currently outside the scope of the CLP Regulation requires careful consideration.

SEMI Europe welcomes Commissions Environmental Omnibus proposals, which aim to simplify and harmonise environmental legislation. While the proposals represent a positive step forward, overlapping obligations, legal uncertainties, and administrative burdens persist, particularly in the areas of Substances of Concern (SoC), Digital Product Passport(DPP), FGases, and the Packaging and Packaging Waste Regulation (PPWR).

SEMI members recognise that the existing F-Gas Regulation has been very successful in reducing the damaging effect of high GWP gases entering the atmosphere. The Regulation strikes a careful balance between encouraging industry to switch to lower GWP gases (where technically possible) and the potential negative impact to EU industry competitiveness on the world market.

The semiconductor industry in Europe, represented by SEMI Europe, welcomes the ambitions of the Chips Act 2.0 to strengthen the European Unions economic competitiveness, supply chain resilience and technological capabilities.

The European Chips Act marked a bold and timely response to these challenges. By combining strategic investment, publicprivate cooperation, and a coordinated policy framework, the Act has already mobilised significant resources to strengthen Europes semiconductor ecosystem and reduce its exposure to external shocks.

SEMI Europe welcomes the opportunity to provide its feedback on the intended revision of the REACH Regulation. We would like to submit comments on the following policy options: • Revision of the registration requirements • Simplifying communication in the supply chain • Reforming the authorization process/Reforming the restriction process Please find our full feedback in the attached file.

SEMI Europe is the European affiliate of SEMI, the industry association representing more than 2,500 semiconductor and electronics manufacturing companies worldwide. SEMI Europe appreciates the opportunity to provide feedback to the European Commission on the Cyber Resilience Act (CRA). Please find our position in the attached document.

SEMI Europe welcomes the opportunity to contribute to the development of harmonised rules for calculating and verifying recycled content in plastic packaging under Article 7(8) of the Packaging and Packaging Waste Regulation.

SEMI Europe, the industry association representing 3,500+ companies globally and 300+ companies in Europe from the entire semiconductor supply chain, provides extensive feedback on the "Draft Commission guidance on the Cyber Resilience Act," please refer to the annex document attached for a complete overview.

SEMI Europe welcomes the European Commissions efforts in developing an EU legislative framework to support the quantum ecosystem in Europe and further strengthen Europes digital capabilities. Considering the similarity between the proposed structure of the upcoming Quantum Act and the existing European Chips Act, a future legislative framework must carefully consider the specificities of the rapidly evolving quantum…

SEMI Europe welcomes the opportunity to participate in the open public consultation on the proposed Regulation on Machinery Products. SEMI Europe also appreciates Commission’s efforts to ensure coherence with the new legislative framework (NLF) and to reduce the costs of transposition with the choice of a Regulation.

SEMI, the association representing the global electronics manufacturing industry, welcomes the opportunity to comment on the revision of the Machinery Directive. AI technologies are already used in semiconductor manufacturing: Using artificial intelligence (AI) tools, today’s semiconductor fabs combine equipment know-how and manufacturing statistics to manage massive fault detection data, increase manufacturing…

On a general note, SEMI understands that this proposal is part of the one substance one assessment (OSO) approach to improve the efficiency, effectiveness, coherence and transparency of issuing safety assessments of chemicals across different pieces of EU legislation, as proposed in the Chemicals Strategy for Sustainability (CSS) under the European Green Deal.

SEMI Europe, representing 3000+ global and 300+ European companies in the microelectronics supply chain, welcomes the opportunity to comment on the proposed delegated regulation under the EU Battery Regulation (EUBR).

SEMI Europe, representing the entire semiconductor value chain in Europe and globally, welcomes the opportunity to provide feedback on the European Commissions proposed regulatory measures on Medium Chain Chlorinated Paraffins (MCCPs) under Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs).

SEMI Europe acknowledges the European Commissions legislative proposal for a revision of the current Foreign Direct Investment (FDI) Screening Regulation (Regulation 2019/452), as an effort to improve the effectiveness of the current legislation.

SEMI Europe, representing the entire semiconductor value chain in Europe and globally, welcomes the opportunity to provide feedback on the European Commissions proposed regulatory measures concerning long-chain perfluorocarboxylic acids (LC-PFCAs) under Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs).

SEMI, representing the electronics manufacturing industry, welcomes the opportunity to give feedback on the roadmap. We see the following areas of improvement: i) RoHS and REACH inconsistencies; ii) global aspect of RoHS; iii) retention of Large-Scale Stationary Industrial Tools (LSSIT) and Large-Scale Fixed Installations (LSFI) exclusions, and importation of used equipment; and iv) the issues surrounding…

SEMI Europe welcomes the evaluation of Regulation (EU) 2021/821 and the opportunity to provide evidence on its effectiveness, efficiency, relevance, coherence and EU added value. The semiconductor value chain is globally integrated. Companies operate across multiple EU and non-EU jurisdictions, use distributed digital infrastructure and collaborate through cloud-based engineering and research environments.