PFAS and the future of semiconductor manufacturing
Per- and polyfluoroalkyl substances (PFAS) are deeply embedded in semiconductor manufacturing and remain essential to the performance, precision and reliability of many critical fabrication processes. From photolithography and etching to packaging and final assembly, PFAS are used across process chemistries, coatings, lubricants, surfactants, heat transfer fluids and equipment components.
The semiconductor industry widely recognizes both the importance of PFAS and the growing scrutiny surrounding their use. For semiconductor manufacturers, PFAS now represent more than an environmental compliance issue. They are becoming a broader operational and strategic consideration that could influence water infrastructure, facility planning, waste management, supply chains and long-term resilience.
Why proactive PFAS management matters
As semiconductor production expands globally, manufacturers face increasing pressure to understand how PFAS move through their operations and how future regulations could affect manufacturing processes and wastewater systems as well as asset planning.
PFAS are not a single chemical, but a diverse class of fluorinated compounds with varying behavior, persistence and toxicity. Some PFAS-containing materials — particularly precursor compounds — may degrade over time and create long-term waste management risks through releases to leachate, air emissions or residual waste streams.
At the same time, many semiconductor manufacturers are still working to build a comprehensive, facility-wide understanding of where PFAS may exist across operations and supply chains. That complexity is compounded by the scale of global sourcing networks and the technical challenges associated with identifying and characterizing PFAS compounds.
For multinational manufacturers operating fabrication facilities across multiple jurisdictions, this creates a difficult balancing act. Designing highly localized responses to evolving regulations can lead to inconsistent operational standards, fragmented procurement decisions and costly retrofits. Overdesigning for uncertain future requirements, however, can significantly increase capital and operating costs.
Rather than reacting to regulations one at a time, many leading organizations are beginning to adopt more adaptive and forward-looking strategies. These approaches include monitoring regulatory developments and evaluating multiple future scenarios while incorporating flexibility into facility planning and water infrastructure decisions.
Planning ahead before regulations arrive
Today, most semiconductor manufacturers are not yet required to implement comprehensive PFAS monitoring or treatment programs. Instead, organizations are asking more foundational questions:
- Where are PFAS present across supply chains, operations, water systems, air emissions and waste streams?
- Which waste streams represent the greatest long-term risk?
- How could future regulations affect facilities being designed today?
- What level of readiness is appropriate while requirements continue to evolve?
Addressing these questions early allows organizations to plan deliberately instead of reacting under regulatory pressure. It also helps align PFAS strategies with broader business priorities, including water reuse, sustainability commitments, cradle-to-grave liability management and long-term asset planning.
For new facilities, this often begins with stream segregation, utility planning and reserving physical space and electrical capacity for future treatment systems. Even without selecting a specific treatment technology, designing flexibility into infrastructure today can significantly reduce the cost and disruption of future upgrades.
In our experience, comprehensive site water management planning enables advanced manufacturing facilities to balance evolving compliance requirements with long-term operational goals. A phased approach also allows facilities to account not only for PFAS, but for other emerging contaminants as regulations and treatment technologies continue to evolve.
Existing facilities face a different set of challenges. Limited segregation opportunities and legacy infrastructure often require more targeted monitoring, forensic analysis and tailored treatment strategies to better understand PFAS sources and movement throughout the site.
Evaluating treatment technologies realistically
The PFAS treatment market is evolving rapidly, with new technologies frequently promoted as breakthrough solutions offering higher removal efficiencies, lower energy use or smaller equipment footprints.
While some technologies show promise, many have limited operating histories under the complex flow conditions and water chemistries typical of semiconductor manufacturing. Long-chain PFAS treatment technologies are generally more established, while treatment for short-chain and ultra-short-chain PFAS — which are especially relevant to the semiconductor industry — remains a significant technical challenge.
Co-contaminants such as nanoparticles, fluoride, ammonia and copper further complicate treatment decisions and can affect technology performance.
For an industry built on precision and reliability, uncertainty itself becomes a risk.
Selecting the right treatment strategy requires more than chasing the latest technology. A structured, data-driven evaluation process helps organizations assess feasibility, operational reliability, lifecycle costs, energy demand and residuals management before making major capital investments.
Independent testing and pilot-scale validation remain essential. These evaluations help manufacturers understand how technologies perform under realistic operating conditions and reduce the risk of investing in systems that may not satisfy future regulatory expectations.
Integrating PFAS into broader water stewardship strategies
Water reuse is already central to semiconductor manufacturing. Modern fabrication facilities rely on increasingly complex water ecosystems that include incoming supply, reclaimed water systems, wastewater treatment and municipal infrastructure.
As water stress intensifies in many manufacturing regions, high reclamation and recycling rates are becoming increasingly important for operational continuity and long-term growth. Yet the sensitivity of semiconductor manufacturing processes means even trace contaminants in reclaimed water can affect product quality and reliability.
PFAS introduce another layer of complexity. Although PFAS historically have not been a primary design driver for water reuse systems, their persistence raises important questions about accumulation, breakthrough and downstream impacts within both environmental systems and process water loops.
Some semiconductor manufacturers also continue discharging wastewater to publicly owned treatment systems, creating additional considerations for municipalities and industrial users alike. Aligning expectations across public and private stakeholders can help manage shared risks while supporting sustainable economic growth.
Increasingly, leading organizations are beginning to incorporate PFAS considerations into broader water and wastewater strategies rather than treating them as a standalone issue. That includes evaluating how PFAS move through manufacturing and treatment systems, how residuals are managed as well as how centralized and decentralized infrastructure interact over time.
From uncertainty to informed action
The semiconductor industry has repeatedly adapted to changing materials, process chemistries and environmental requirements. PFAS represent the next major test of that adaptability.
Organizations that take a structured, risk-based and flexible approach today will be better positioned to navigate evolving regulations while maintaining operational resilience and protecting long-term investments.
Effective PFAS management is no longer solely about immediate compliance. It is becoming part of a broader strategy for resilient manufacturing, sustainable water management and future-ready infrastructure.
This article appears in the Q2 2026 issue of EM Plus Magazine, a copyrighted publication of the Air & Waste Management Association (A&WMA; www.awma.org).
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Global Principal, PFAS and Emerging Contaminants, Environmental
Dora Chiang brings global PFAS expertise, helping clients understand risk, shape strategy and deliver effective solutions to complex contamination challenges across investigation, assessment and remediation programs.
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Industrial Water Global Principal
Brian supports clients across industries as they navigate risks with water scarcity, environmental regulations, corporate social responsibility and aging infrastructure.
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Senior Process Engineer
Brad is a technical leader in water management for the semiconductor industry, with more than 30 years of experience in ultrapure water and wastewater treatment. He supports clients as they plan and implement resilient water strategies for advanced manufacturing facilities.
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Solutions Leader, Emerging Contaminants
Garrett specializes in PFAS and emerging contaminants, supporting clients to understand and reduce risk through site investigation, remediation and treatment solutions. He brings nearly a decade of global experience advancing practical, science-based approaches to PFAS and emerging contaminant detection, treatment and product stewardship.
