SEMI publishes nine-point position paper urging EU to widen Chips Act 2.0 beyond fabs

SEMI has published a position paper setting out nine policy recommendations for the EU's Chips Act 2.0, urging European co-legislators to extend the legislation's scope well beyond semiconductor fabs to cover design, materials, equipment, manufacturing, and advanced packaging^[1]. The paper was released as the draft regulation moves through the EU's co-legislative process, following the European Commission's formal proposal on 3 June 2026^[1].

A broader definition of "first-of-a-kind"

The central ask in SEMI's paper is an expansion of the EU's First-of-a-Kind (FOAK) framework. The Commission's draft already allows FOAK state aid for projects spanning raw materials to packaging^[1], but SEMI wants the definition widened further so that incentives reach more segments of the value chain, including chip design tools, process materials, specialty chemicals, and equipment^[1].

The first European Chips Act mobilised more than €52 billion in public and private investment and created an estimated 46,000 direct and indirect jobs. Despite that progress, the EU remains dependent on third countries in key areas such as advanced chip manufacturing and semiconductor design^[1]. SEMI's position is that the successor legislation must close those gaps structurally, not just at the fab level.

"Europe's semiconductor competitiveness depends on the strength of the entire ecosystem, from design and materials to equipment, manufacturing and advanced packaging," said Laith Altimime, President of SEMI Europe. "The Chips Act 2.0 provides an important opportunity to build on Europe's existing strengths."^[1]

Speed, cost, and governance

Beyond the FOAK question, SEMI's recommendations address three practical constraints that have slowed semiconductor investment in Europe^[1]:

• Permitting and investment timelines - SEMI is calling for faster and more predictable procedures, a concern that has surfaced repeatedly as European projects have lagged behind US and Asian counterparts in time-to-production.
• Production costs - The paper flags Europe's higher semiconductor manufacturing costs as an increasingly important competitive factor and asks that demand-side initiatives align with existing industry structures rather than creating parallel systems.
• Governance - SEMI wants greater industry participation in Chips Act oversight bodies and what it describes as an ambitious but balanced EU budget for the programme^[1].

The global semiconductor market is projected to reach €1.37 trillion by 2030, with AI-related components driving around 70% of that growth.

Supply chain monitoring and skills

Two further recommendations target resilience and workforce. SEMI is proposing secure, industry-led semiconductor supply chain monitoring to replace the current approach, which it regards as insufficiently responsive to fast-moving disruptions^[1]. On skills, the paper calls for stronger workforce development measures - a long-standing gap in Europe's semiconductor ecosystem that the first Chips Act did not fully address^[1].

SEMI represents more than 4,000 companies across the global electronics design and manufacturing supply chain, giving its position paper reach beyond semiconductor manufacturers to equipment makers, materials suppliers, and design-tool vendors^[1].

The legislation is now in the hands of the European Parliament and Council. SEMI has said it will continue engaging with EU institutions and member states throughout negotiations. The key question for the industry is whether co-legislators accept the broader FOAK definition and faster permitting timelines - two changes that would directly affect how quickly European chip projects can move from approval to first wafers.