Questions & Answers

Hazardous Waste

Question:

Thank you for the EIA article about the Norwegian hazardous substance restrictions at http://www.eiatrack.org/r/1568.

Freescale manufactures microcontrollers, sensors, microprocessors, and many other types of semiconductor chips. The primary markets for our chips are automotive, telecommunication, industrial and consumer products. Most of these products are covered under RoHS or ELV.

While I do not expect legal advice, I would value any insight into the intent of the bill as it relates to semiconductors.

* Semiconductor chips are used in EEE (RoHS & WEEE), but they are not themselves classified as EEE. Do you think the bill intends to cover the B2B sale of components for EEE?
* Semiconductor chips are not typically classified as consumer products, so they may not be covered. Is the bill intended to only cover consumer products?
* Certain high performance semiconductor chips are printed on gallium arsenide materials instead of silicon. Would Norway to incorporate any exemptions for this form of ‘bound’ arsenic?
* Certain semiconductor manufacturing processes use perfluorinated compounds, including PFOA. This material is removed from the final chip during subsequent fabrication processes. Assuming the fabrication occurs outside of Norway, do you expect Norway to prohibit the sale of these products?

The article raises these alarms. I appreciate any insight you can offer on these topics.

Answer:

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