Policy Briefing — European Chips Act Proposal Unveiled
The European Commission’s 8 February 2022 Chips Act package pushed semiconductor organisations to prioritise operational resilience, governance, and sourcing alliances across the EU value chain.
Executive briefing: On 8 February 2022 the European Commission unveiled the Chips Act package, combining a proposed regulation, a recommendation, and significant funding to bolster Europe’s semiconductor ecosystem. The package targets three pillars: strengthening research and technology leadership, ensuring security of supply, and establishing crisis response mechanisms. Semiconductor manufacturers, design houses, equipment suppliers, and downstream industries must align operational strategies, governance models, and sourcing decisions with the Act’s objectives to access incentives and comply with new coordination requirements.
Policy landscape
The Chips Act proposes a framework for state aid supporting “first-of-a-kind” fabs, expands Joint Undertakings for R&D, and creates a coordination mechanism for monitoring supply chains and responding to crises. Funding instruments include the Chips for Europe Initiative, leveraging Horizon Europe and the Digital Europe Programme, and the Important Projects of Common European Interest (IPCEI) on microelectronics. Member States are encouraged to adopt national strategies aligned with EU goals, while companies accessing aid must meet transparency, reporting, and security obligations.
Operational priorities
Industry players should focus on:
- Capacity planning. Evaluate potential investments in advanced nodes, specialty chips, and packaging facilities within the EU. Analyse demand forecasts, talent availability, and infrastructure requirements to build bankable proposals.
- Supply chain visibility. Map upstream suppliers of wafers, chemicals, gases, and equipment, identifying single points of failure. Implement digital twin models to simulate disruptions and optimise inventory buffers.
- R&D collaboration. Engage with research centres, universities, and pilot lines funded through the Chips for Europe Initiative to accelerate innovation in photonics, quantum, and energy-efficient semiconductors.
- Workforce development. Design training programmes, apprenticeships, and mobility schemes to attract engineers, technicians, and operators, leveraging EU talent funding where possible.
Operational plans should incorporate sustainability considerations, including energy consumption, water management, and circular economy practices demanded by EU climate policies.
Governance and compliance
Boards and executive committees must ensure alignment with Chips Act governance expectations:
- State aid governance. Establish compliance frameworks for receiving public support, including record-keeping, reporting, and audit readiness. Document how funded projects deliver spillover benefits and adhere to security-of-supply commitments.
- Crisis response integration. Participate in the EU Semiconductor Board’s early warning mechanism, designate crisis coordinators, and integrate EU reporting obligations into business continuity plans.
- Cybersecurity and IP protection. Implement robust security controls to protect intellectual property and production systems, aligning with the EU Cybersecurity Act and NIS2 Directive expectations.
- Stakeholder engagement. Coordinate with national authorities, industry associations, and social partners to align investments with regional development goals and workforce policies.
Governance structures should incorporate metrics on localisation commitments, resilience performance, and compliance milestones.
Sourcing and partnership strategies
The Chips Act incentivises collaborative sourcing across the ecosystem:
- Strategic partnerships. Form alliances with materials suppliers, equipment manufacturers, and design IP providers to co-invest in capacity and innovation. Structure agreements to share risk, secure supply, and align on ESG standards.
- Supplier diversification. Identify alternative sources for critical inputs such as rare gases, photoresists, and advanced lithography equipment. Evaluate reshoring or near-shoring options within the EU or trusted partners.
- Public-private partnerships. Participate in IPCEI consortia and European Digital Innovation Hubs to access funding, pilot lines, and expertise. Prepare detailed project plans demonstrating cross-border collaboration.
- Downstream collaboration. Engage automotive, aerospace, and industrial customers in long-term demand agreements to justify investment and share risk.
Procurement teams should incorporate resilience criteria into supplier scorecards, including geographic diversity, sustainability performance, and contingency planning.
Technology and infrastructure
Companies planning new fabs or expansions must address infrastructure challenges:
- Utilities management. Secure reliable energy, water, and waste treatment capacity, exploring renewable power purchase agreements and recycling technologies to meet EU sustainability targets.
- Digitalisation. Deploy advanced manufacturing execution systems (MES), Industrial IoT sensors, and AI-driven process controls to enhance yield, traceability, and predictive maintenance.
- Security-by-design. Integrate physical and cyber security measures into facility design, including access controls, intrusion detection, and secure network segmentation.
- Supply chain traceability. Implement blockchain or advanced data platforms for tracking materials and components across the value chain, supporting regulatory reporting and customer assurance.
Infrastructure plans should align with national permitting requirements and environmental impact assessments.
Risk management
Semiconductor organisations must manage strategic and operational risks:
- Geopolitical risk. Monitor export controls, trade tensions, and sanctions that could impact technology transfers or market access. Develop contingency plans for supply disruptions involving East Asian manufacturing hubs.
- Financial risk. Conduct scenario planning for capex overruns, demand fluctuations, and currency volatility. Evaluate insurance options and hedging strategies.
- Compliance risk. Track evolving EU regulations on sustainability, data protection, and worker safety that intersect with semiconductor operations.
- Innovation risk. Balance investments across mature and emerging technologies, assessing time-to-market and potential obsolescence.
Risk registers should feed into board discussions, with mitigation strategies tied to budget allocations and partnership decisions.
Metrics and reporting
Establish KPIs to monitor Chips Act alignment:
- Capital expenditure committed to EU-based facilities versus planned targets.
- Percentage of critical materials sourced from diversified suppliers.
- Participation in EU-funded research projects and resulting patents or prototypes.
- Workforce development metrics, including training hours and talent retention.
- Production resilience indicators such as yield variance, downtime, and inventory coverage.
Reporting should support EU Semiconductor Board engagement, investor disclosures, and sustainability reporting frameworks such as the CSRD.
Forward look
During 2022 the Commission launched a Chips Act pilot for the semiconductor observatory, collecting monthly data from manufacturers on capacity utilisation, inventory levels, and raw material constraints. Organisations that participate can influence crisis indicators and gain early visibility into policy tools such as priority orders or export transparency measures. Align internal analytics with observatory templates to reduce reporting friction.
The Chips Act legislative process involves negotiations between the European Parliament and Council, with implementation anticipated from 2023 onwards. Companies should monitor amendments concerning state aid thresholds, crisis measures, and foreign investment screening. Coordination with other initiatives—such as the Important Projects of Common European Interest on cloud and edge computing, and the Digital Markets Act—will influence market dynamics. Early movers that embed governance, operational resilience, and sourcing collaboration will be best positioned to capture incentives and shape Europe’s semiconductor future.
Key resources
- European Commission Communication on the European Chips Act
- European Chips Act Package Overview
- EU Digital Strategy: Semiconductors in Europe
Zeph Tech helps semiconductor leaders align with the EU Chips Act through scenario modeling, partnership orchestration, and compliance analytics.
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