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16/01/2015 – Page 4 of 18

PZT description:

PZT designates Lead Zirconium Titanate which is an intermetallic inorganic

compound with the chemical formula Pb[ZrxTi1-x]O3 (0≤x≤1). It is a white solid that is

insoluble in all solvents. Such compound is a ceramic perovskite material that shows

the following remarkable properties:

- a marked piezoelectric effect, which finds practical applications in the area of

electroceramics

- a high dielectric constant especially which can range from 300 to 3850

depending upon orientation and doping, the material featuring an extremely large

dielectric constant at the morphotropic phase boundary near x = 0.52

- being pyroelectric, this material develops a voltage difference across two of its

faces when it experiences a temperature change. As a result, it can be used as a

heat sensor

- it is also ferroelectric, which means it has a spontaneous electric polarization

(electric dipole) which can be reversed in the presence of an electric field.

Duration where applicable:

We apply for renewal of this exemption for categories 1 to 7, 10 and 11 of Annex I for

an additional validity period of 5 years. For these categories, the validity of this

exemption may be required beyond this timeframe. Although applications in this

exemption renewal request may be relevant to categories 8 & 9, this renewal request

does not address these categories. Further, categories 8 & 9 have separate maximum

validity periods and time limits for application for renewals.

Other: Background:

While exemption 7c of the Annex to the RoHS Directive would no longer cover the use

of Lead in low voltage applications in the 2011 review, an exemption was requested in

2010 since FRAMS (Ferroelectric Random Access Memory) and MIM

(Metal/Insulator/Metal) capacitors using PZT-based dielectric ceramic materials may be

operated in the low voltage area. This is the reason of this recent exemption 7(c)-IV.

This exemption was justified with the following arguments:

1) Lead-zirconium-titanate (PZT) material has the highest known dielectric

constant (εr = 1000 – 1200) and thus can be used as a planar

Metal/Insulator/Metal (MIM) capacitor with a breakdown voltage of more than 100

V. No alternative to PZT is currently known for thin film capacitors and

Ferroelectric Random Access Memory (F-RAM) memories that achieves the same

combination of high dielectric constant, high breakdown field and temperature

stability of 20% in a temperature range from -25 to +85 °C. This combination of

properties is indispensable to realize capacitors as parts of integrated circuits and

discrete semiconductors.

16/01/2015 – Page 5 of 18

2) Alternatives to PZT based dielectric ceramic capacitors are not available. Trench

capacitors have a breakdown of less than 30 V only, no MIM is possible. Other

potential alternatives such as Barium-Strontium-Titanate (BST) have only half

the dielectric constant, which results in much larger devices that do not meet the

size dimensions of semiconductor applications. Performance characteristics with

alternatives are severely degraded. These potential alternative techniques (trench-

or BST-capacitors) are not able to fulfil the electric requirements that are needed

for such applications, a high breakdown voltage and low internal resistance at low

leakage currents and high capacitance values. New materials without Pb will have

to be invented.

3) Within the dielectric circuit element of the capacitor, the level of lead content is

very low. The amount of lead introduced into the EU per year is in the order of 25-

30kg for the considered ROHS applications. Lead in PZT in this case is present in

trace amounts.

3. Summary of the exemption request / revocation request

Renewal of Exemption No. 7(c)-IV for thin film PZT deposited on semiconductor

devices as stated above.

Note:

IPD: Integrated Passive Device

FeRAM or FRAM: Ferroelectric Random Access Memory.

FRAM module - Courtesy of Texas Instruments

IPD on silicon - Courtesy of STMicroelectronics

16/01/2015 – Page 6 of 18

4. Technical description of the exemption request / revocation request

(A) Description of the concerned application:

1. To which EEE is the exemption request/information relevant?

Name of applications or products:

Integrated circuits or discrete components that include dielectric ceramic

materials for capacitors.

a. List of relevant categories: (mark more than one where applicable)

1 7

2 8

3 9

4 10

5 11

6

b. Please specify if application is in use in other categories to which the

exemption request does not refer:

Although applications in this exemption renewal request may be relevant to

categories 8 & 9, this renewal request does not address these categories.

Therefore, we have not completed section 4(A)1.c. Further, categories 8 & 9

have separate maximum validity periods and time limits for application for

renewals.

c. Please specify for equipment of category 8 and 9:

The requested exemption will be applied in

monitoring and control instruments in industry

in-vitro diagnostics

other medical devices or other monitoring and control instruments than

those in industry

n/a

2. Which of the six substances is in use in the application/product?

(Indicate more than one where applicable)

Pb Cd Hg Cr-VI PBB PBDE

3. Function of the substance:

Dielectric material with specific properties for high density capacitors.

4. Content of substance in homogeneous material (%weight):

< 1% of the semiconductor die taken as homogeneous material

16/01/2015 – Page 7 of 18

5. Amount of substance entering the EU market annually through application for

which the exemption is requested: < 27.5 kg / year (superior limit)

Please supply information and calculations to support stated figure.

Calculation:

The Yole production forecast 2012-2018 for IPDs, FeRAMs and MEMS

(Micro Electro Mechanical System) combined in number of 6’’ eq. wafers

shipped for the thin film PZT market represents 578,000 (6’’ eq.) in 2012 and

is estimated to be 533,700 (6’’ eq.) wafers by 2018.

Based on this forecast, a yearly worldwide average estimation over 2014-2020

can be set at 550,000 wfs (6’’ eq.) /year, including MEMS.

Estimated weight Pb x 6” wafers: 50 mg maximum (superior limit)

Estimated weight Pb in devices annually sold to market: 550,000 x 50 mg ~

27,5 kg for the worldwide market.

The amount of substance entering the EU market annually through application

for which the exemption is requested is much inferior to 27,5 kg while this

result applies to the global market, includes the MEMS and bounds from

above the mass of PZT deposited on the wafers.

6. Name of material/component:

Material: Lead Zirconium Titanate also called PZT, an intermetallic inorganic

compound with the chemical formula Pb[ZrxTi1-x]O3 (0≤x≤1), see description

in paragraph 2.

Components: Integrated Circuits or Discrete Semiconductors for

application categories 1 through 7, 10 & 11 listed in annex I of current ROHS

directive.

7. Environmental Assessment:

LCA: Yes

No

After the manufacturing process, the PZT is bound in a crystalline and

insoluble form. When the components are assembled on the printed circuit

board of the application, the PZT will never be released.

According to our current knowledge, the functionality and long lifetime

guaranteed for the components made with PZT cannot be achieved with any

alternative substance or mixture of substances.

((B) In whic

for wh

of this

Pb is p

below,

device

Source: 2

Pb is a

Sources:

ch material

ich you req

material o

present on

including b

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2013 Yole report

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: Switch Science

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e, Egloos, Texa

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PZT as a p

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silicon chip

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that "only

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devices ar

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the only

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thin film

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5. If

1

Informatifrom EEE

1) Please

exists

to ensu

Articles

manufa

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disman

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The rem

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f this exem

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he EEE was

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s outside th

EEE are eith

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2015 – Page 1

reparations for app

loop syst

ation of its

hod of trea

mption are

ot the man

ste.

re recycled

rial collectio

in the EU i

appropriatel

e Member S

her:

enterprises

enterprises

dual waste

10 of 18

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em exist fo

s character

atment, etc

e not end

ufacturers

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ly managed

State of orig

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s and impro

(e.g. to land

se or rec treatmen

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ristics (me

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products

of the end

furbished. S

metals, or la

ported by co

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gin).

rly treated

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f waste te

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16/01/2015 – Page 11 of 18

http://epp.eurostat.ec.europa.eu/portal/page/portal/waste/key_waste_streams/wa

ste_electrical_electronic_equipment_weee

In general there is no closed loop system, just on-customer basis related to

specific sectors.

2) Please indicate where relevant:

Article is collected and sent without dismantling for recycling

Article is collected and completely refurbished for reuse

Article is collected and dismantled:

The following parts are refurbished for use as spare parts:

The following parts are subsequently recycled:

Article cannot be recycled and is therefore:

Sent for energy return

Landfilled

Articles object of this exemption are not end products and as such therefore

answering to this question is irrelevant

Note: Some EEE are recycled and/or refurbished. Some Equipment are disposed

as part of residual waste (e.g. to landfill or incinerators).

3) Please provide information concerning the amount (weight) of RoHS sub-

stance present in EEE waste accumulates per annum:

In articles which are refurbished

In articles which are recycled

In articles which are sent for energy return

In articles which are landfilled

Note: while the total content of Lead in EE products put on the worldwide market

in 2013 can be estimated at around 9,000 t, the estimated superior limit of Pb in

devices with PZT thin film components is 27.5 kg, representing annually not more

than about 3 ppm of the total weight of Lead introduced on the worldwide market.

16/01/2015 – Page 12 of 18

6. Analysis of possible alternative substances

(A) Please provide information if possible alternative applications or

alternatives for use of RoHS substances in application exist. Please

elaborate analysis on a life-cycle basis, including where available

information about independent research, peer-review studies

development activities undertaken

No possible alternative substance matching PZT dielectric properties can be

found in the current state of material physics knowledge.

See section 7(B) and the following reports:

- Öko-institute Final report - revised version - Freiburg, 28 July 2010:

"Adaptation to scientific and technical progress of Annex II to Directive

2000/53/EC (ELV) and of the Annex to Directive 2002/95/EC (RoHS)"

- Yole: "Thin Film PZT for Semiconductor - Application trends &Technology

update (FeRAM, IPDs and MEMS)" – 2013

(B) Please provide information and data to establish reliability of possible

substitutes of application and of RoHS materials in application

n/a (no possible substitute)

7. Proposed actions to develop possible substitutes

(

(

(A) Pleas

possi

subst

The

altern

conclu

voltag

The Ö

(B) Pleas

subst

stage

Subst

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suppl

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se provide

ible alterna

tances in t

Yole Thin

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ge (see belo

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se elaborat

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titute mater

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iers on th

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16/01/2

informatio

atives for th

he applicat

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th identify

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ctor Industr

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2015 – Page 1

n if actions

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develop a

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specified

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material req

ted materia

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t predict

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th tantalite

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and BST ha

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ble betwee

P

-40C to +

≥ 40 yea

1E12 r/w

1700 [2]

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High-dielectr

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ologies:

apacitors co

citors.

2015 – Page 1

quirement s

l suppliers

ogether with

After a mate

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um titanate

O9) - mater

d, but no fi

wer perform

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BS

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~10 years

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t Thin Films

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potential alte

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materials, w

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mer sampli

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ials in orde

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which are ev

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Requirem

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>40 years

Unlimited c

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16/01/2

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nstitute:

to costs,

expensive

s on other p

2015 – Page 1

gies Fit in T

PZT for Semicon

:

according

alternative

piezo materi

15 of 18

erms of De

nductor"

to Yole r

to PZT thin

ials are:

nsity Versu

report (pag

n film techno

s Applicatio

ge 75), 3D

ology.

on?

D trench

8. J

(

(

Justificat

(A) Links t

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[1] L

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used

2) Prov

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Authorisa

Lead Titan

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Restrictio

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much less th

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ports stated

16/01/2

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SVHC [1

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ium Zirconi

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stitution:

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2015 – Page 1

Article 5(

ce + substit

provisions a

1]

ate list [1]

al inclusion A

XIV

ium Oxide

EC 235-038

XVII

of intention

d while PZT

y in the scop

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information

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nder 4.(A)2

ces?

n: No substit

6. (A) and r

16 of 18

(1)(a):

tute)

apply to the

Annex XIV

/ EC 235-7

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ns

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received th

be eliminat

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racts inserte

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AS 12626-8

article and/

(27.5 kg su

supply chai

operties exis

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ed under

81-2 and

/or used

ubstance

n.

st.

orm.

16/01/2015 – Page 17 of 18

2. Can the substance named under 4.(A)2 be substituted?

Yes.

Design changes:

Other materials:

Other substance:

No.

Justification: No substitutes with required properties exist.

See reports stated in section 6. (A) and related extracts inserted in this form.

3. Give details on the reliability of substitutes (technical data + information): n/a

4. Describe environmental assessment of substance from 4.(A)1 and possible

substitutes with regard to

1) Environmental impacts: n/a

2) Health impacts: n/a

3) Consumer safety impacts: n/a

Do impacts of substitution outweigh benefits there of?

Please provide third-party verified assessment on this: n/a

(C) Availability of substitutes:

a) Describe supply sources for substitutes: n/a

b) Have you encountered problems with the availability? Describe: n/a

c) Do you consider the price of the substitute to be a problem for the

availability?

Yes No (n/a)

d) What conditions need to be fulfilled to ensure the availability?

Same physical dielectric and ferroelectric properties.

(D) Socio-economic impact of substitution:

What kind of economic effects do you consider related to substitution?

No substitute available with similar physical properties

Increase in direct production costs

Increase in fixed costs

Increase in overhead

Possible social impacts within the EU

Possible social impacts external to the EU

Other:

16/01/2015 – Page 18 of 18

Provide sufficient evidence (third-party verified) to support your statement:

See reports stated in section 6. (A)

9. Other relevant information

Please provide additional relevant information to further establish the necessity of

your request:

No substitute material with equivalent physical properties.

10. Information that should be regarded as proprietary

Please state clearly whether any of the above information should be regarded to as

proprietary information. If so, please provide verifiable justification: n/a