Safeguarding the Semiconductor Industry

Supply Chain Risks and Foreign Dependency due to PFAS-Related Regulatory Uncertainty

The semiconductor industry is on track to become a $2 trillion global market by 2030, driven by unprecedented demand across technology sectors. Yet, with this growth comes increasing scrutiny from regulatory agencies worldwide. The United States Environmental Protection Agency (USEPA), European Union Environmental Chemicals Agency (ECHA), Organization for Economic Co-operation and Development (OECD) and many others are introducing restrictions and prohibitions of chemicals critical to the semi-conductor and microelectronics industries, making proactive product stewardship not just prudent, but essential. 

PFAS: A Critical and Complex Challenge 

One critical regulatory challenge facing the industry is the categorization of PFAS based on chemical structure which results in management of thousands of chemicals, many unrelated when considering chemical and physical properties (encompassing gases, fluids and polymers). Some of the PFAS highly valued for their stability and performance are deeply and irreplaceably integrated into the semiconductor manufacturing processes. However, many PFAS are also under sweeping regulatory review due to their persistence in the environment, potential for human health impacts, and, possibly, the mere fact they fall under a broad chemical structure definition. In many cases, regulatory restrictions can severely disrupt both chemical manufacturers and downstream industries that rely on these substances. 

Adding complexity, many U.S. states are enacting their own PFAS regulations. For instance, Maine has finalized a rule that will restrict all new and unused products containing intentionally added PFAS, unless exempt through a Currently Unavoidable Use (CUU), beginning January 1, 2026. Manufacturers whose products fall under approved CUU determinations must now file a PFAS Notification Form and pay the required fee if they wish to keep selling, offering, or distributing those products in Maine after the sales ban begins on January 1, 2026. Minnesota has also proposed a rule that would restrict intentionally added PFAS in all products starting January 1, 2032, unless designated as a Currently Unavoidable Use (CUU). Manufacturers would be required to report such uses by July 1, 2026. Recently, the Washington State Department of Ecology adopted amendments for stricter restrictions and reporting of PFAS. These amendments introduced restrictions on intentionally added PFAS in three product categories (apparel and accessories, automotive washes, and cleaning products) and introduced reporting requirements in nine other product categories. New restrictions from this rule take effect on January 1, 2027. Similar initiatives are underway in New Mexico, signaling a trend toward extensive, onerous and potentially disruptive localized regulation. 

While some of these frameworks include “essential use” exemptions – often applicable to semiconductor manufacturing – these protections are temporary, provide little guidance on how to maintain critical uses and do not secure the end-to-end chemical supply chain, including the many chemical intermediates needed for manufacturing.  

Manufacturers must act now to: 

1. Assess which PFAS are truly critical to semiconductor production; 
2. Map the supply chain to determine the sources of the critical PFAS, as well as their chemical intermediates and processing aides required for their manufacture; and 
3. Prepare to mitigate emerging business risks such as chemical obsolescence and foreign sourcing from China and US adversaries.  

This understanding allows companies to pinpoint their regulatory vulnerabilities, bolster their supply chains, employ proactive product stewardship practices and prioritize seeking alternatives for those substances with the greatest human health, environmental and supply chain risks. In addition to research for alternatives, investment is needed to improve manufacturing abatement technologies, especially for those PFAS for which there is a high barrier to identifying and transitioning to an alternative. By engaging with suppliers and regulators, industry can help shape policies that protect human health and the environment while minimizing disruption to innovation and supporting domestic manufacturing. 

Industry Collaboration and Advocacy  

At SEMICON West 2025, a leading global conference for the semiconductor and microelectronics industry, Dr. Tricia Underwood, Vice President of TRC’s Strategic Health Sciences, addressed growing regulatory requirements, supply chain challenges and proactive stewardship opportunities. She served as a panelist with four other representatives of industry stakeholders to discuss the supply chain challenges that the semiconductor industry should be aware of when considering its procurement, use and disposal of regulated or soon to be regulated chemicals. Her key takeaway messages included: 

1. Avoid regrettable substitutions by conducting comprehensive life cycle assessments that evaluate chemical alternatives, including the intermediate chemistries and processing aids needed in the manufacturing process.  
2. Evaluate all tradeoffs (safety, performance, cost, societal benefits) when considering PFAS alternatives, not only as they pertain to the intended use, but also in the context of broader public health concerns. 
3. Plan to responsibly manage ongoing PFAS critical uses through improvements in abatement technologies as transition times for drop-in replacements can be a decade or more into the future.