July 20, 2020
Tokyo Electron Limited
EHS Promotion Center

Our View on Management of Chemical Substancesin Tokyo Electron Group ProductsContents
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PURPOSESCOPE
DEFINITIONS
AWARENESS OF HAZARDOUS SUBSTANCES AND THEIR MANAGEMENTEXEMPTION OF INVESTIGATION BASED ON THE FORMAT SPECIFIED BY TELREVISION AND OTHER POINTS

1. PURPOSE
In accordance with the basic environmental policies of Tokyo Electron Group (hereinafter referred to as TEL),
the company established the Green Procurement Guidelines in January 2001 in order to manufacture
environment-friendly products. TEL then launched the Compliance-with-RoHS Activity in 2006 to ensure thecompany voluntarily conforms to the EU RoHS directive. The China RoHS directive was enforced in March
2007 and EU REACH was enforced in June of the same year, kicking off a new era of chemical substancecontrol. Similar laws and regulations have also been enacted and are enforced in other countries. In Japan, too,
the movement toward stricter management of chemical substances has started through enactment of the Revised
Act on Evaluation of Chemical Substances and Regulation of Their Manufacture, etc. In order to ensurecompliance with the above-stated laws and regulations on chemical substances, TEL brings our view onmanagement of chemical substances into operation. This view applies, as part of green procurement, toprohibition and management of chemical substances contained in components used in TEL products, andauxiliary materials incidental to production such as solvents.

2. SCOPE
This procedure applies to management of chemical substances (simply called substances) contained in procured
components used in TEL products, jigs shipped together with TEL products, and shaped products (also calledarticles) such as packaging materials.

3. DEFINITIONS
3.1

TEL Managed Substances Group
This term refers to all substances that fall under any of the following categories: TEL prohibited substances,
TEL restricted substances, TEL mandatory managed substances, and TEL general managed substances.
Applicable substances shall be designated by the TEL Contained Substance Steering Meeting. If the same
substance is included in two or more lists, priority regarding its categorization shall be given in the order of1

TEL prohibited substances, TEL restricted substances, TEL mandatory managed substances, and TEL
general managed substances.
3.2TEL Prohibited Substances

3.2.1 Substances prohibited by international regulations
Every group listed in Annexes A, B and E, and Group II of Annex C in the Montreal Protocol on Substancesthat Deplete the Ozone Layer
3.2.2 Substances that are legally prohibited in countries TEL operates in
3.2.3 Substances that TEL voluntarily prohibits
3.3TEL Restricted Substances
These are six substances designated in the RoHS directive 2011/65/EU. However, TEL does not apply theexemptions admitted depending on the intended use stated in the RoHS directive. The six substances andtheir threshold values are shown below.
① Cadmium and cadmium compounds [100 ppm]
② Lead and lead compounds [1000 ppm]
③ Mercury and mercury compounds [1000 ppm]
④ Hexavalent chromium compounds [1000 ppm]
⑤ Polybromobiphenyl (PBB) [1000 ppm]
⑥ Polybrominated diphenyl ethers (PBDE) including Decabromodiphenyl ether (DecaBDE) [1000 ppm]
⑦ Bis(2-ethylhexyl) phthalate (DEHP) [1000 ppm]
⑧ Butyl benzyl phthalate (BBP) [1000 ppm]
⑨ Dibutyl phthalate (DBP) (0,1 %) [1000 ppm]
⑩ Diisobutyl phthalate (DIBP) (0,1 %) [1000 ppm]

3.4

TEL Mandatory Managed SubstancesThis term refers to substances that TEL specified, from the chemSHERPA Managed Substance List
(hereinafter referred to as the chemSHERPA Management List), and from legally restricted substances inother countries, as those for which management is mandatory.

3.5

TEL General Managed SubstancesThis term refers to substances TEL specified from the chemSHERPA Management List (see 3.12.) as thosefor which information must be communicated.

3.6

TEL Substances Group List

3.6.1 About the TEL Substances Group List
The TEL Substances Group List is a list of substances included in the TEL Managed Substances Group. Thislist was developed based on the substance names and other information. In the list, the chemSHERPAManagement List is in principle used as the main reference source. For details, see Attachment "TEL
Substances List".
3.6.2 Supplement: On use of the chemSHERPA Management List
Since the chemSHERPA Management List is incorporated into the chemSHERPA data entry support tool for
articles / chemicals provided by JAMP, almost all the substances in the TEL Managed Chemical SubstancesGroup can be checked using this system. However, coverage of the list in the support system is limited to the2practical domain. Therefore, before presenting a final reply to TEL, the person in charge of reporting theinclusion must refer to the TEL Substances Group List for confirmation purposes.
3.6.3 Examples of the substances to be managed for which provision of information is required:① Carcinogenic, reprotoxic and mutagenic substances listed in EU CLP Regulation Annex VI Table 3.2.
<Category 1 and Category 2>② Restricted substances listed in EU REACH Annex XVII (excluding ① above).
③ Substances listed in EU REACH Annex XIV that require approval, and their candidates.
④ Other substances, excluding ①, ② and ③ above, that are regulated by domestic or international
regulations.
3.7

Chart Explaining Relationships between Types of Substances in the TEL Managed Chemical SubstancesGroupThe chart shows the relationships between the substances described in 3.1 to 3.5 above.

TEL Managed Substances Group
General chemical substances
TEL general managed substances
TEL mandatory
managed substances
TEL
restrictedsubstances

3.8

TEL
prohibitedsubstances

EU RoHSThis is the abbreviation for the EU directive "Restriction of the use of certain Hazardous Substances inElectrical and Electronic Equipment". Visit the following URL for details.
https://j-net21.smrj.go.jp/development/rohs/basic/basic.html

3.9

EU REACH
This is the abbreviation for Registration, Evaluation, Authorization and Restriction of Chemicals. This is a
new regulation concerning chemical substances that was enacted on June 1, 2008. Visit the following URL
for details.
https://www.meti.go.jp/policy/chemical_management/081127gaiyou.pdf

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3.10

Format Specified by TELThis term refers to the Contained Chemical Substances Inspection Format used by TEL. TEL uses thechemSHERPA-AI format, the format recommended by JAMP to use to communicate information about
substances contained in shaped products.
3.11 JAMP
This is the abbreviation for Joint Article Management Promotion consortium. Visit the following website fordetails.
https://chemsherpa.net/english/jamp/about
3.12 chemSHERPA Managed Substance List
https://chemsherpa.net/tool#declarable
3.13 Shaped Product (Article)
This term refers to an object that has a specific shape, surface or design that exerts a greater influence on its
function than its chemical composition does.

4. AWARENESS OF HAZARDOUS SUBSTANCES AND THEIR MANAGEMENT
4.1

TEL Prohibited Substances
TEL prohibits inclusion of these substances in products. If a regulatory standard has been defined, theconcentration - including impurities - must be below the standard.

4.2

TEL Restricted Substances
TEL prohibits inclusion of these substances in products. If a regulatory standard has been defined for thetarget substances, the inclusion level must be below the threshold value. However, in spite of the foregoing,
delivery of products containing quantities of substances beyond the threshold levels shall be permitted if
such inclusion is reported using the format specified by TEL.

4.3

TEL Mandatory Managed SubstancesThis term refers to substances for which the relevant suppliers must be aware of inclusion levels. With theexception of prohibited and restricted substances, TEL does not immediately restrict inclusion of substances
contained in this group in products. Rather, TEL mandates that suppliers submit to TEL data on use andinclusion levels of relevant substances that is obtained via investigation based on reasonably maximum
possible efforts. In cases where TEL is subject to legal regulations, TEL manages the applicable substances
based on facts known to it.

4.4

TEL General Managed SubstancesThis term refers to substances included in the chemSHERPA Managed Substance List. Such substances
include TEL prohibited substances, TEL restricted substances, and TEL mandatory managed substances.
TEL does not immediately restrict inclusion of substances contained in this group in products. Rather, TEL
requires suppliers to submit data on the inclusion levels of such substances to TEL when "the inclusion isknown". TEL sets the substances contained in this group as the managing target when "the inclusion isknown". "The inclusion is known" means that "TEL has received information from an upstream supplier(e.g., a raw material manufacturer) in the supply chain about the fact that a target substance of management4

is included", or that "TEL has confirmed in some way that such substances are included". TEL may restrictor prohibit use of specific substances based on facts known to it.

5. EXEMPTION OF INVESTIGATION BASED ON THE FORMAT SPECIFIED BY TEL
On the condition that the following requirements are satisfied, suppliers are exempted from submitting
investigation results using the format specified by TEL:
5.1

Suppliers must define the responsibility and procedures in document format to satisfy the requirements
described in the "Guidelines for the management of chemical substances in products" published by JAMP in
relation to items and details of management actions concerning information on chemical substances
contained in products.

5.2

Suppliers must evaluate their conformity to the "Guidelines for the management of chemical substances inproducts" published by JAMP. Based on the judgment, suppliers issue and submit a self-declaration ofconformity to TEL, attached with the JAMP Guidelines for the Management of Chemical Substance inProducts Annex - List of Action Items and Check Sheet (hereinafter referred to as the Guideline CheckSheet).

5.3

TEL checks the Guideline Check Sheet to confirm the validity of the self-declaration of conformity, andverifies that the management system has been constructed as demanded by TEL.

5.4

If the delivered items do not contain any chemical substances that TEL must manage, that is, TEL prohibited
substances, TEL restricted substances, and TEL mandatory managed substances, the supplier is exemptedfrom providing the relevant information using the format specified by TEL.

5.5

If TEL has specified an additional chemical substance(s) about which information must be reported in orderto observe laws, regulations, or other rules applicable in Japan or other related countries, the supplier must
immediately check that the delivered items do not contain the specified chemical substance(s). If the supplierhas discovered that the substance(s) is contained, the supplier must report the relevant fact using the format
specified by TEL and cooperate to ensure conformity when requested by TEL.

6. REVISION AND OTHER POINTSTEL revises the TEL Substances Group List and other information as needed.

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