🧪 Semiconductor × PFAS — Corporate Response Case Studies

3M is a major US materials company that has made PFAS since the 1950s. In December 2022 it announced that it would exit PFAS manufacturing entirely by the end of 2025 and work to stop using PFAS across its product portfolio. In its annual report, the company states that it completed its exit from PFAS manufacturing at the end of 2025. Ending PFAS use across its products, however, is still under way: products that use PFAS-containing parts made by third parties, such as lithium-ion batteries, printed circuit boards, and certain seals and gaskets, will remain after 2025, according to the company. The environmental NGO ChemSec points out that 3M removed PFAS from about 7,000 products over the past three years (roughly one third), while about 14,000 products that contain PFAS are still being made. As part of the exit, last orders for fluorinated fluids such as Novec™ were taken on March 31, 2025, and manufacturing ended at the end of 2025.

DuPont is a US chemical company supplying materials to fields such as healthcare, water treatment, construction, and transportation. It states that it does not manufacture PFOA, PFOS, or GenX, and in its 2019 commitments it pledged to eliminate the use of long-chain PFAS in recently integrated operations (by the end of 2019) and the use of PFAS in firefighting foams at its own sites (by the end of 2021). It says its own PFAS use is a small fraction of global use and that it pursues alternatives where alternatives exist. At the same time, responsibility for past PFAS contamination has not disappeared through the separations of Chemours in 2015, Corteva in 2019, and Qnity Electronics in November 2025. Under a 2021 memorandum of understanding (MOU), Chemours bears 50%, and DuPont and Corteva together bear 50%, of future PFAS liabilities arising from conduct before July 1, 2015; in the Qnity separation, too, certain liabilities, including PFAS liabilities, were contractually allocated to Qnity.

Daikin Industries is a major manufacturer of fluorochemical products, including fluoropolymers and fluoroelastomers, in addition to air-conditioning equipment, and it supplies materials to industries such as semiconductors, automotive, medical, and HVAC/refrigeration. It is a member of the Fluoropolymers Product Group (FPG), which calls for fluoropolymers to be fully exempted from the restriction proposal, but the March 2026 RAC final opinion included fluoropolymers within the scope of the restriction. The company has invested more than $300 million in recovering PFAS from wastewater at its manufacturing sites worldwide, has achieved its internal target of recovering 99% of polymerization emulsifiers in fluoropolymer manufacturing in the US and Europe, and is aiming for a 99.9% PFAS recovery rate at all of its plants. On the process side, it began producing fluoroelastomers (FKM) without fluorinated surfactants in 2025. Meanwhile, groundwater PFOA contamination continues around the Yodogawa plant (Settsu, Osaka), which manufactured PFOA until 2012; in addition to pumping and treating groundwater, the company has been building a barrier wall since 2023 to prevent outflow beyond the site. In December 2025, residents living near the plant filed for pollution mediation against the company, which commented that it will consider its response through constructive dialogue.

Chemours is a chemical company spun off from DuPont in 2015, making fluorochemical products such as Teflon™ (fluoropolymers), Nafion™ (ion-exchange membranes), and Opteon™ (low-GWP refrigerants). At the spin-off it took on much of the responsibility for past PFAS contamination, and it shares PFAS-related costs with DuPont and Corteva under a 2021 memorandum of understanding. The company has set a goal of cutting process emissions of fluorinated organic chemicals (FOCs) to air and water by 99% or more from 2018 levels by 2030, and its 2025 sustainability report reported an 80% reduction. At the same time, at Fayetteville Works in North Carolina, where GenX contamination has been an issue, it applied in August 2025 to revise its air permit to allow increased production of vinyl ethers, which it says are essential for semiconductors, batteries, and defense; downstream local governments and others oppose the application.

AGC is a materials maker in glass and chemicals; its chemicals business manufactures fluoropolymers (PTFE, ETFE, and others), fluoroelastomers (AFLAS®), and fluorinated solvents (AsahiKlin™). Fluoropolymers for Europe are made by its UK subsidiary AGC Chemicals Europe (Thornton-Cleveleys). As a member of the FPG, the company has argued that fluoropolymers should not be regulated together with other PFAS, but the March 2026 RAC final opinion included fluoropolymers within the scope of the restriction. With 3M having ended production of Novec™, the hydrofluoroether solvent AsahiKlin™ AE-3000 is used as a Novec replacement, but this solvent also qualifies as PFAS under the OECD definition. On the process side, the company has developed a fluoropolymer manufacturing process that does not use surfactants and has launched new grades of FFKM (AFLAS®) made without surfactants or fluorinated polymerization solvents. At its UK plant, an investigation by public authorities into the potential release of PFOA from the former ICI-era site is under way, and in Japan, in June 2026, Ichihara City announced that PFOS and PFOA above the national provisional guideline value had been detected in observation wells within the AGC Chiba Logistics Center site and in a nearby park. AGC says the cause and pathway have not been identified.

Syensqo is a specialty chemicals company that became independent from Solvay in 2023, making fluoropolymers (PVDF, PTFE, FKM, FFKM, and others) and the high-performance fluorinated fluid Galden® PFPE. According to the company, the majority of its fluoropolymer production is made without fluorinated surfactants. At Spinetta Marengo in Italy, it uses a limited amount of a next-generation fluorosurfactant (C6O4) and plans to move almost 100% to non-fluorosurfactant (NFS) technology by 2026. In 2025 it launched what it calls the world's first FFKM made without surfactants (Tecnoflon®). Galden® PFPE, meanwhile, is offered as a replacement fluid after 3M's exit from Novec™, but PFPE itself is also PFAS. At Spinetta Marengo, two former plant managers are to stand trial on charges of negligent environmental disaster, and in the US, for the West Deptford plant in New Jersey, the company has committed in a settlement with the state to payments of about $393 million, among other obligations.

Arkema is a French specialty chemicals company that makes Kynar® PVDF, among other products; Kynar® is a fluoropolymer used in lithium-ion batteries and water filtration, among other applications. On April 30, 2025, the company announced that at all of its production sites it makes Kynar® PVDF using only non-fluorinated surfactants, with no fluorinated surfactants. At the Pierre-Bénite plant south of Lyon, it stopped using its last PFAS surfactant (6:2 FTS) at the end of December 2024, and had already cut its discharges to water by more than 90% with a filtration system introduced in 2022. Meanwhile, administrative and judicial proceedings with residents and environmental groups continue over past PFAS emissions from the plant. In January 2026, a summons from residents and groups in the Lyon area was served on the company, which says it will contest it.

BASF is the world's largest chemical company, and states that it does not synthesize carbon-fluorine bonds in its manufacturing processes and is not engaged in fluorine chemistry. It also says it has a limited number of products formulated with PFAS. In May 2023 it adopted a position on PFAS, and it states a policy of phasing out chemical products formulated with PFAS, excluding crop protection. No deadline for the phase-out is stated, but the company's internal sustainability guidance sets five years, that is, by 2028 (according to a November 2025 report by the environmental NGO ChemSec). It manages progress with its own TripleS (Sustainable Solution Steering) method, and says it applies the scope of the EU PFAS restriction proposal even in regions such as those outside the EU that have no law regulating PFAS individually. Meanwhile, Ciba Specialty Chemicals, which it acquired in 2009, made and sold fluorosurfactants for firefighting foam (AFFF) until 2003, so BASF, as its legal successor, is a defendant in US AFFF litigation, and in May 2024 it agreed to contribute $316.5 million to a class settlement with public water systems.

Shin-Etsu Chemical holds one of the world's leading shares in silicon wafers for semiconductors and also supplies lithography materials such as photoresists and photomask blanks. It began producing KrF photoresists in 1997 and has since expanded into ArF resists, multilayer materials and EUV resists. Many of the photoacid generators (PAGs) that give photoresists their photosensitivity contain PFAS, and the Semiconductor PFAS Consortium of the Semiconductor Industry Association (SIA) notes that replacing them with non-PFAS PAGs requires reformulating the resist as a whole. For uses that are hard to substitute, the EU's PFAS restriction proposal provides time-limited derogations of 5 or 12 years following an 18-month transition period from entry into force (6.5 or 13.5 years in total from entry into force), and derogations without a time limit are also proposed for some uses. Which period will apply to semiconductor uses will be settled by SEAC's final opinion, expected at the end of 2026, and the European Commission's subsequent decision. In April 2024, the company announced a fourth production site for lithography materials in Isesaki, Gunma Prefecture; the first phase (about ¥83 billion) was completed in April 2026, and construction of the second phase has begun.

Fujifilm is a company that applies technology developed in photographic film to semiconductor materials, supplying photoresists among other products. The company explains that in photoresists for ArF immersion exposure, PFAS have been used to make the acid reactions needed to draw fine circuit patterns more efficient and to give the resist surface water repellency that suppresses defects caused by water remaining on the wafer. In April 2024 it announced a nanoimprint resist that contains no PFAS (on sale from late May of that year), and in July 2025 it announced a negative-tone ArF immersion resist that uses no PFAS at all. For the latter, it says that in a joint evaluation with imec it demonstrated that 28nm-generation metal wiring can be formed with high yield and high throughput; as of July 2025, customer evaluations were under way and the company aimed for an early launch. In April 2026 it announced that it had developed, for the first time in the world, a fluorine-free negative-tone ArF immersion resist that uses no organic compounds with carbon–fluorine bonds as raw materials, not only PFAS, and began providing samples. No timing has been given for adoption of the ArF immersion resists in volume production.

Resonac is a materials maker formed in 2023 through the merger of the former Showa Denko and Hitachi Chemical. Its semiconductor and electronic materials business handles high-purity gases, CMP slurries, and encapsulants, among other products. Its high-purity gases include fluorocarbon gases used for semiconductor etching and for cleaning deposition tools (C₄F₈, C₄F₆, C₃F₈, C₂F₆, and CF₄), which are PFAS under the OECD definition. Other gases in the same product line (high-purity hydrogen fluoride (HF), fluorine/nitrogen mixed gas, silicon tetrafluoride (SiF₄), and sulfur hexafluoride (SF₆)) contain no carbon, and fluoromethane (CH₃F) contains no fully fluorinated carbon, so none of them are PFAS. In response to PFAS regulation, Resonac's Integrated Report 2024 says the corporate planning department acts as secretariat and is surveying PFAS use across the group, estimating the scale of the impact, gathering and analyzing customer and regulatory trends, and developing and exploring alternatives. On its chemical management page, the company says it plans to establish a new policy addressing social issues including PFAS and to review its controlled substances, and its 2026 target is to establish the "Resonac Policy" (this has not yet been completed). On the product side, it proposes a UV-curable non-fluorinated water- and oil-repellent coating agent as an alternative to fluorinated coating agents (the page was updated on August 6, 2024), and says it can be expected to impart water and oil repellency equivalent to fluorinated coating agents, with no significant difference in static contact angle compared with PTFE (a product under development). How the gases for semiconductors will be treated under the EU's PFAS restriction proposal will depend on the final content of the restriction.

Tokyo Electron (TEL) is a Japanese semiconductor equipment maker supplying etch, deposition, and coater/developer tools, among others. It does not make PFAS, but semiconductor manufacturing uses fluorocarbon gases for etching (CF₄, C₄F₈, and others) and fluorinated heat transfer fluids for temperature control in tools. In its 2023 report, the Semiconductor PFAS Consortium of the Semiconductor Industry Association (SIA) says that, for heat transfer fluids, there is currently no non-PFAS alternative that meets all the required performance at once for some applications. On its environment page, TEL says it will investigate whether PFAS are contained and then promote substitution, and its Integrated Report 2025 also says it works to gather information on PFAS and other regulations earlier and respond. For etching, TEL's official blog (October 2024) says a cryogenic process can replace 91% of CF gases with hydrogen fluoride (HF) gas, process contact holes deeper than 10 μm 2.5 times faster than before, and cut power consumption by more than 40%. The blog gave, as of August 2024, an outlook of low-volume production in 2025 and high-volume production in 2026, but at its July 30, 2026 earnings briefing TEL explained that mass deployment of cryogenic etch tools for 400-layer NAND will start in CY2027. According to press reports, SK hynix is evaluating with test wafers and Samsung with a demo tool (May 2024). Note that the replacement rate is 91%, so the use of CF gases does not disappear entirely.

TSMC is the world's largest semiconductor foundry and uses PFAS-containing materials in processes such as photolithography, etching and cleaning. It manages PFAS through four strategies: source control, industry cooperation, environmental monitoring and pollution control. For new raw materials, suppliers must declare that their materials contain no PFAS with more than four fluorinated carbon atoms, while PFAS with four or fewer must be disclosed to TSMC for management. In 2018, the company replaced PFOA-related substances with short-chain PFAS of four carbons or fewer, and it is evaluating the elimination of PFAS with more than four carbons from photolithography chemicals. For wastewater, each plant has PFAS treatment systems, and by March 2025 TSMC had deployed its own analysis method (filtration-direct analysis) at all of its fabs in Taiwan and overseas, cutting detection time from 105 minutes to 15 minutes.

Samsung Electronics is one of the world's largest memory makers, with semiconductor manufacturing sites in South Korea and Texas, and it also runs a foundry business. Chip manufacturing uses PFAS-containing materials in lithography, etching and cleaning processes and in equipment cooling. According to its sustainability report, the semiconductor (DS) division surveyed PFAS use across all raw material suppliers and is working toward PFAS-free status by identifying and introducing alternative substances. Its semiconductor website also states that it manages materials under internal standards reflecting international environmental regulations and continuously monitors new regulatory trends such as PFAS. Following 3M's exit from fluorinated coolant production, Chinese chemical makers have reportedly begun supplying coolants to Korean chipmakers, including Samsung.

Intel is a US-based semiconductor maker whose primary production fabs in 2025 were in Arizona, Oregon, Ireland and Israel. Leading-edge logic manufacturing uses PFAS-containing materials in lithography materials, etching gases and equipment parts. As a founding member of the Semiconductor Industry Association's (SIA) Semiconductor PFAS Consortium, the company has contributed to technical white papers that map how PFAS are used in chipmaking and where alternatives may be possible. In 2022, it established an internal policy restricting the use of certain PFAS as fab materials. Meanwhile, the Chemical Users Coalition, an industry group whose members include Intel and IBM, submitted comments on Maine's proposed PFAS-in-products rule, and the company weighs in on the scope and procedures of state regulation through such groups.