SEMI Europe Publishes Recommendations for the REACH Revision

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SEMI, the industry association serving the global electronics design and manufacturing supply chain, released its official position paper on the revision of the European Union’s REACH Regulation. The paper outlines the semiconductor industry’s priorities for ensuring that the revised regulation supports sustainable manufacturing in Europe while protecting the technological resilience and competitiveness of Europe’s semiconductor industry.

“Semiconductors are at the core of Europe’s green and digital transition, and the REACH revision must reflect the unique role our industry plays in enabling this future,” said Laith Altimime, President of SEMI Europe. “This paper highlights how a more tailored, risk-based approach to regulation can ensure continued access to critical materials, foster innovation, and uphold the EU’s leadership in sustainable manufacturing.”

The REACH revision proposal is expected in Q4 2025. With key regulatory decisions approaching, SEMI Europe is calling for a balanced and forward-looking framework that enables both environmental protection and technological progress.

Key recommendations from SEMI Europe include:

• Introducing sector-specific derogations and realistic transition timelines for complex industrial sectors such as semiconductors.
• Ensuring restriction decisions are based on full risk assessments that account for real-world use and exposure, rather than hazard alone.
• Avoiding mandatory polymer registration for proprietary process chemicals already governed under existing frameworks.
• Applying substance grouping and substitution planning with greater scientific precision, especially for critical-use substances.
• Clarifying and operationalizing the essential use concept in a transparent, proportionate, and industry-relevant manner.
• Strengthening nanomaterials regulation through targeted updates to safety data sheets, testing guidelines, and integration of the revised EU definition.

The paper also highlights the importance of ensuring that the REACH revision does not conflict with strategic EU initiatives, including the European Chips Act, and calls for deeper engagement between regulators and high-technology industries in shaping effective, innovation-compatible policy.

“SEMI Europe stands ready to work with EU institutions, regulators, and relevant stakeholders to ensure the REACH revision reflects both scientific evidence and the operational realities of the semiconductor sector,” said Altimime. “By aligning regulatory ambition with industrial capabilities, Europe can achieve its sustainability goals while preserving long-term strategic resilience.”