Chapter III Pillar Two: Security of Supply

and the acquisition of foreign specialists (outside the EU) must be addressed in order to achieve the fastest possible implementation at EU level. Therefore, this should not be optional, but a must. In addition, the cross-border connection of semiconductor manufacturing companies with technical students from BSc to PhD levels within the Union should be facilitated.

Article 4 – Objectives, Paragraph 2e and Article 5, Paragraph 1e – Chips Fund

Summary of Paragraphs

The Initiative shall have ‘Chips Fund’ activities for access to debt financing and equity to startups, scale-ups, SMEs and other companies in the semiconductor value chain by InvestEU and

Accelerator programmes of the EIC.

Evaluation

We endorse the chips fund. The minimum investment of 2 bn. Euro is only mentioned in the EU Chips act communication. Only the InvestEU and EIC together of 425 Mio. Euro are mentioned directly in the act. We recommend a clarification of the finance volume in the act.

Article 7 – EU Chips Infrastructure Consortium

Summary of Paragraph

The Initiative for a European Chips Infrastructure

Consortium (‘ECIC’) may be established as a public private consortium, that is specifically developed to simplify and structure the legal relationships between the private-public consortium members, including particularly RTOs, and provide a structural dialogue with the Commission for the implementation of the actions under the

Initiative. This new legal instrument is voluntary.

Evaluation

We welcome that the ECIC is designed as a public-private consortium. Nonetheless, the principles of EU competition policy should be strictly observed in the implementation of the ECIC. If set up, the role of the ECIC compared to other existing public-private associations like INSIDE, Aeneas should be clarified. However, the benefits of establishing a large number of newly created committees are not yet clear to us. In addition, the participation of the Alliance on Processors and Semiconductor technologies should be clarified.

Chapter III Pillar Two: Security of Supply

Article 10 and 11 – Integrated Production Facilities and Open EU Foundries

Summary of Paragraphs

Integrated Production Facilities and open EU

Foundries, which are first-of-a-kind semiconductor design and manufacturing facilities, have priority access to the pilot lines. Besides, open EU

Foundries must establish and maintain adequate and effective functional separation by working with undertakings not related to their own facility.

Evaluation

In principle, we think the division into EU Open Foundries and Integrated Production Facilities makes sense. The scope of the instrument is sufficiently broad to allow for projects which are in line with the needs of the EU key industries. It is important and good that the required evolution path towards the “next generation of chips“ is not narrowly defined either, so that innovations across different technologies can be targeted.