REACH Threatens To Make GaAs Extinct
GaAs chips are a multi-billion dollar industry. Amplifiers made from this material are used in most handsets and portable devices plus many defence applications, and lasers based on GaAs are the key technology in DVD and CD players and recorders, as well as in repeaters for fibre optic communications.
However, the European sector of this important industry is now under threat, due to a new European initiative by the Risk Assessment Committee (RAC) of the European Chemicals Agency (ECHA). The proposed REACH Regulation and the RoHS Directive 2002/95/EC would be a massive blow to the industry.
The concern is that the GaAs semiconductor industry in the EU would be put at a substantial competitive disadvantage compared with non-EU countries. Furthermore the GaAs industry fears that the more stringent classification might have other impacts, for example, resulting in restricted investments by banks and customer prejudices.
The use and disposal of GaAs are already ruled by stringent laws and the industry already takes environmental protection and health requirements very seriously in both the manufacture and disposal of GaAs and other compound semiconductors.
What is not clear is whether the Commission is aware of the doubts and arguments of the industry regarding the more stringent classification of GaAs. And if so, what does the Commission know about the semiconductor industry's concerns about restrictions of GaAs under the REACH Regulation and a substance ban under the RoHS Directive? In addition, there are uncertainties regarding the impact of the lack of an effective alternative material for many applications on a decision about an authorisation requirement, restrictions, or a substance ban.
Also it is not known if the Commission has assessed the pre-impacts and impacts of a potential restriction of GaAs on the competitive standing of the EU industry concerned. Furthermore, it is unclear if it shares the position that there is no alternative to GaAs in certain fields of the semiconductor industry, such as in high-frequency technology.
InP is another compound semiconductor material that has been affected by the directive. This costly but unique material is used in high-speed internet and long wavelength lasers; there are currently no viable mass production alternatives for certain applications. Unfortunately though, InP has already been condemned by the 2010 RAC opinion without any objections from industry. This will result in many painful regulations including RoHS and REACH.
The compound semiconductor industry clearly does not want the same thing happening to GaAs based products. This was the second compound semiconductor to be threatened by a 2010 RAC opinion. However, this time,there have been strong objections from Freiburger Compound Materials (FCM), a German-based global provider of GaAs substrates, among other firms.
The EU Commission has directed ECHA to reopen public consultation about the alleged potential carcinogenic nature of GaAs, which was an unprecedented result according to experts in the III-V industry.
From 11th March till 25th April 2011, the GaAs industry can submit objections to the RAC opinion on the “Classification,Labellingand Packaging"(CLP) classification of GaAs. This is not exactly a favourable period, to say the least. Currently, the decision on potential further steps by ECHA is pending.
To focus on the fight against the additional regulations, a GaAs Industry Team (GAIT) has been set up and has arranged for support from two renowned US toxicologists for GAIT’s task to comment. In addition, a well renowned specialist on cancer research from Europe has committed to prepare a literature evaluation on the case.
Many within the III-V industry believe that the RAC appears to be risking its scientific reputation; it has made major omissions and misrepresentations and frankly, inaccurate conclusions in its judgement on the “hazardous potential" of GaAs. For instance, less than 0.2% of the weight of a mobile phone is GaAs and the user is unlikely to do themself any harm unless they decide to eat the chip. However, the Commission still seems to be reluctant to openly address this deficiency.
The RAC opinion on the reproductive toxicology (reprotox) classification, although absurdly flawed in the minds of many, has not actually been reopened for public consultation. This would make it difficult to avoid a “Substances of Very High Concern"listing for GaAs. After the objections so far filed however, it does now appear that RAC is intending to formally admit, at most, a certain lack of a public consultation that was requested by the REACH directive. But that just isn’t good enough.
The claim that “zero thresholds" determine the hazardous potential of substances is promoted by RAC for application in other areas of regulatory work such as ecotoxicology. It looks like GaAs is just the next in line for the chopping block.
On the plus side, there are currently many activities in progress which are focusing on making the authorities responsible for REACH and CLP understand what Europe could stand to lose under the current proposals.
More details on GAIT and increasing the campaign’s fire power against the legislation against GaAs can be obtained from Hermann Schenk at FCM (Europe) or John Sharp at TriQuint (TQS, US).
Affected parties can also put political pressure on the EU DG Environment and DG Enterprise organisations by requesting that they:
- Support an unbiased toxicological evaluation based on reasonable scientific reasoning
- Re-open the case on reproductive toxicity
- Recognise the socio-economic importance of GaAs
The Editorial team at Compound Semiconductor.net encourages all readers raise the issue with their national government and, if appropriate, with their representative in the EU parliament urging the European Commission for a parliamentary inquiry, as well as seekingsupport from other EU Member states (e.g. France, UK, Scandinavia)
According to leaders in the GAIT committee however, so far, attempts to meet with the French competent authority (AFSSET) have been turned down.
Apart from European-based firms, the GAIT industry team includes many US-based members and currently includes personnel from Anadigics, Avago, FCM, IPC, IQE, WIN, RFMD, Rockwell Collins, Skyworks, Texas Instruments, TriQuint and UPS.