SIA Highlights Low Risk of Forced Labor in Semiconductor Supply Chains

SIA testified today at a hearing convened by the U.S. Department of Homeland Security (DHS) on methods to prevent the importation of goods mined, produced, or manufactured from regions of concern into the United States. The hearing was convened pursuant to the recently enacted UFLPA, legislation that designated polysilicon – a material used to create solar panels and semiconductor wafers – as a high-priority enforcement area.

SIA supports global efforts to ensure the semiconductor supply chain remains free of forced labor, while at the same time ensuring that the UFLPA does not lead to unnecessary supply chain disruptions and put America’s leadership in this foundational and indispensable technology at risk.

SIA’s testimony highlighted the low risk of forced labor involved in the type of polysilicon used in semiconductor manufacturing. The polysilicon produced in regions of concern currently does not meet the extremely high levels of purity required for semiconductor-grade polysilicon. The global production of semiconductor-grade polysilicon is concentrated among five major manufacturers: Wacker Chemie (Germany), Hemlock Semiconductor (U.S.), Tokuyama Corporation (Japan), Mitsubishi Corporation (Japan), and REC Silicon (based in the U.S., listed in Norway). Wacker Chemie and Hemlock Semiconductor account for approximately three-quarters of the global semiconductor polysilicon supply. Of these manufacturers, confirmed sources of the metallurgical-grade silicon for semiconductor-polysilicon production include the United States, Brazil, Malaysia, France, Germany, Norway, South Korea, and Australia, none of which are regions of concern.

The testimony reflected comments filed by SIA on March 25 calling on DHS to 1) promulgate clear and actionable guidance that considers the low risk that semiconductor supply chains involve forced labor and 2) increase information sharing and transparency to help industry and suppliers strengthen compliance efforts.

SIA will continue to work with DHS, the Forced Labor Task Force, and other partners to develop and implement clear and actionable guidance that offers the predictability industry needs both to fulsomely address forced labor issues and to continue to operate this critical supply chain with as few disruptions as possible.