Environmental and Corporate Responsibility Compliance
EU Reduction of Hazardous Substances (RoHS)
(corresponding California Code of Regulations, section 66260.202)
EU Waste Electrical and Electronic Equipment (WEEE)
EU Registration, Evaluation, Authorization and Restriction of Chemicals (REACH)
California Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition 65)
US Toxic Substances Control Act of 1976 (TSCA)
Sourcing Materials from Conflict Regions (Dodd-Frank)
Pure Wafer both resurfaces and recycles customers’ silicon wafers, and offers for sale new and recycled wafers from its own inventory.
Silicon Wafers - are round, thin wafers made from a single crystal of silicon in sizes from two (2) inches to eighteen (18) inches in diameter, usually mirror finished either on one side or both sides. The wafers typically contain deminimus amounts, usually in parts per billion (ppb) levels (rarely in parts per million (ppm) levels) of doped elements such as arsenic, phosphorus and boron. These wafers are not manufactured by Pure Wafer, but are either obtained as recycled or new from a “Prime”.
RoHS, and the California Code of Regulations (CCR)
The Reduction of Hazardous Substances (RoHS) [http://www.rohsguide.com/] is an EU Directive originally issued as (2002/95/EC pertaining to the Restriction of Hazardous Substances in Electrical and Electronic Equipment (EEE). It was adopted by the EU in February 2003 and took effect on the 1st of July 2006. This Directive was brought into force in order to limit the component concentration of six hazardous substances found in EEE as they are harmful to the environment, mainly through the pollution of landfills.
The latest RoHS Directive (EU) 2015/863 published in 2015, amending Annex II to 2011/65/EU (RoHS 2) originally published July 2011, now covers 10 substances, including not only integrated electrical and electronic products but also individual parts, raw materials and packing cases.
This Directive is very closely related to the WEEE Directive (Waste from Electrical and Electronic Equipment (2002/96/EC)) except RoHS regulates hazardous substances in EEE while WEEE regulates the disposal of the same equipment.
Subsequently, the State of California adopted within the California Code of Regulations, Title 22, Division 4.5, Chapter 10, Article 3, §66260.202 Restrictions on the Use of Heavy Metals in Covered Electronic Devices: “(a) On or after January 1, 2007, no person shall sell or offer for sale in California, a covered electronic device if the device is prohibited from being sold or offered for sale in the European Union on or after its date of manufacture due to the concentration of one or more heavy metals in the device exceeding its maximum concentration value, as specified in the Commission of European Communities’ Decision of August 18, 2005, amending Directive 2002/95/EC (European Union document 2005/618/EC), or as specified in a subsequent amendment to the Directive.”
Pure Wafer certifies that its silicon products are compliant with all provisions set forth by RoHS and the California Code of Regulations (CCR) §66260.202, and that the homogeneous material that composes our products contain less than the Maximum Concentration Values for the ten RoHS substances listed.
Pure Wafer silicon products are not subject to EU Directive 2002/96/EC (WEEE). However, we cannot certify the compliance and will not be responsible for any metal coatings or finishes that contain restricted substances that are requested, outsourced, and/or applied by our customers. Pure Wafer cannot, and will not assume, liability for the disposal of processed or modified products. Any product supplied by Pure Wafer that may require future disposal will be the responsibility of the purchaser in accordance with local laws and regulations.
Pure Wafer has evaluated the products it offers regarding their status under Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) EC 1907/2006 when products are put on the market in the European Economic Area (EEA).
Section 2.1 of the ECHA guidance document (Requirements for Substances in Articles) defines an Article as “an object which during production is given a special shape, surface or design which determines its function to a greater degree than its chemical composition”. Pure Wafer products (silicon wafers) meet the definition of an Article in both section 2.1 of the ECHA (European Union) guidance document for REACH, as well as the United States Code of Federal Regulations (OSHA 29 CFR §1910.1200(c)).
Pure Wafer does not manufacture these Articles, and has no control over the material content. However, silicon wafers have been found not to contain any of the 223 Substances of Very High Concern (SVHC) as listed on the last updated January 2022 Candidate List of Substances of Very High Concern [https://echa.europa.eu/candidate-list-table] at concentrations above 0.1% (w/w). Section 4.1 of the ECHA guidance document covers substances in Articles that are: (a) intended to be released from articles during normal conditions of use, and (b) the total amount of the substance produced or imported in all articles exceeds 1 tonne (2,204.6 lbs) per year. The silicon wafers provided by Pure Wafer and covered under this statement do not exceed these limits.
REACH regulations do not require Pure Wafer to register, notify or communicate substance information on products meeting these conditions that are offered in the EEA per section 4.2 of the ECHA guidance document. This statement covers all legitimate products (silicon wafers) offered by Pure Wafer.
California Proposition 65
Proposition 65, officially known as the Safe Drinking Water and Toxic Enforcement Act of 1986, protects the state’s drinking water sources from being contaminated with chemicals known to cause cancer. Silicon wafers typically contain deminimus amounts, usually in parts per billion (ppb) levels (rarely in parts per million (ppm) levels) of doped elements such as arsenic, phosphorus and boron. These wafers are not manufactured by Pure Wafer, but are either obtained as recycled or new from a “Prime”.
Therefore, to the best of our knowledge, if any of the Proposition 65 List of chemicals [https://oehha.ca.gov/proposition-65/proposition-65-list] are present in the silicon wafers provided by Pure Wafer they are below the Safe Harbor Levels.
The U.S. Toxic Substances Control Act of 1976 (TSCA) [http://www.epa.gov/laws-regulations/summary-toxic-substances-control-act] addresses the production, importation, use, and disposal of certain chemicals into or within the United States, and provides the U.S. Environmental Protection Agency (EPA) with the authority to require reporting, record-keeping, and restrictions relating to chemical substances and/or mixtures. To that end, TSCA has established a number of regulatory requirements. These include restricting or prohibiting certain substances, and setting import fees for certain high-priority assessed substances, among other measures. On June 22, 2016, the Frank R. Lautenberg Chemical Safety for the 21st Century Act (Lautenberg Chemical Safety Act) was signed into law amending TSCA.
Under Section 6 [https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/regulation-chemicals-under-section-6a-toxic-substances], the EPA had restricted nine substances or substance families as of midyear 2020. These included PCBs, dioxins, chlorofluoroalkanes, asbestos, lead, mercury, formaldehyde, certain nitrites, and certain uses of hexavalent chromium compounds.
On January 6, 2021, the final rules were published for Section 6(h) of TSCA. These rules restrict companies from distributing the following five toxic substances, or products containing these substances, in U.S. commerce:
- Phenol, isopropylated phosphate (3:1) (PIP 3:1)
- Decabromodiphenyl ether (DecaBDE)
- 2,4,6-tris(tert-butyl)phenol (2,4,6-TTBP)
- Hexachlorobutadiene (HCBD)
- Pentachlorothiophenol (PCTP)
Sourcing Materials from Conflict Regions
Pure Wafer is aware of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Wall Street Reform Act) requirements regarding the sourcing of metals (tin, tantalum, tungsten, gold) from conflict regions.
At this time, to the best of our knowledge, Pure Wafer products do not use materials (tin, tantalum, tungsten, gold) that are sourced from mines in conflict regions in the eastern region of the DRC (“Conflict Regions”).
Pure Wafer requests all our relevant suppliers to source for minerals from regions that are conflict-free and not from The Democratic Republic of Congo (DRC) and its neighboring regions.