DOSSIER № FG-01 / GOVERNANCE & CHAIN OF CUSTODY
F-gas / semiconductors / displays

Who made this molecule?

Every fluorinated gas etched into a chip or a panel arrived from somewhere — a fab, a gas manufacturer, a mine. Brands ask suppliers. Suppliers rarely ask upstream. This dossier maps the chain of custody that should exist, the regulations that already require pieces of it, who's actually disclosing what, and the three places attention is thinnest.

01 — GOVERNANCE & CHAIN OF CUSTODY

The cascade of asking

A brand company cannot see fluorspar in the ground. But it can require each tier to require the next — the same discipline used for conflict minerals, applied to gas instead of ore.

TIER 0 — BRAND

OEM / Brand Company

Requests annual Scope 1 F-gas data (HFC / PFC / SF6 / NF3) from Tier-1 suppliers via CDP Supply Chain, its own supplier code, or a Responsible Business Alliance–aligned scorecard.

TIER 1 — MANUFACTURE

Semiconductor Fab & Display Panel Maker

Must in turn request gas composition, GWP, abatement destruction/removal efficiency (DRE), and volume from its process-gas suppliers — not estimate it internally.

TIER 2 — F-GAS MAKER

Gas Manufacturer / Producer

Discloses production volumes, GWP-weighted emissions and reclaim/recycle participation, ideally per production site, verified by a third party.

TIER 3 — FEEDSTOCK

Fluorspar Mining & HFC Production

The least visible link. Origin of the fluorochemical feedstock, under Montreal Protocol production-quota licensing — almost no public traceability exists here today.

Emissions estimated are not emissions verified.

The platform this needs

Should have

CDP Supply Chain module

Annual questionnaire already carries F-gas fields; the gap is response rate below Tier 1, not the form itself.

Should have

SEMI / WSC PFC reporting

Semiconductor-specific voluntary framework tracking normalized PFC emissions since 1999 — a ready-made backbone.

Must have

Batch-level chain of custody

A CMRT-style template (the conflict-minerals model) doesn't yet exist for F-gas shipments — this is the missing "must," not a "nice to have."

Must have

Third-party verified DRE

Abatement destruction/removal efficiency claims are largely self-reported. Independent verification, at least annually, closes the credibility gap.

02 — INTERNATIONAL REGULATION

What already requires disclosure

No single global F-gas traceability law exists. But these instruments together set most of the obligations a supply chain platform would need to enforce.

2024

EU F-Gas Regulation (EU) 2024/573

Revised HFC phase-down and quota system; tightens reporting for semiconductor-sector SF6 and NF3 use.

European Commission — eur-lex.europa.eu
2016

Kigali Amendment to the Montreal Protocol

Global HFC phase-down schedule, in force since 2019, administered by the UNEP Ozone Secretariat.

UNEP Ozone Secretariat — ozone.unep.org
1987

Montreal Protocol on Substances that Deplete the Ozone Layer

Foundational treaty underpinning all subsequent F-gas / ozone-related control regimes.

UNEP — ozone.unep.org
2020

US AIM Act & EPA SNAP Program

Domestic HFC allocation and phasedown implementing Kigali in the United States.

US EPA — epa.gov
JP

Japan Fluorocarbons Emission Control Law

Mandatory leak detection and reporting for fluorocarbon-handling equipment; semiconductor guidance via JEITA.

Ministry of the Environment, Japan — env.go.jp
CN

China HFC Quota Allocation (Dual Carbon roadmap)

Implements Kigali domestically with a phase-down schedule extending to 2045.

Ministry of Ecology and Environment — mee.gov.cn
TW

Taiwan Semiconductor PFC Emission Control

Sector-specific control given the concentration of leading-edge fab capacity on the island.

Ministry of Environment, Taiwan — moenv.gov.tw
IPCC

IPCC AR6 Working Group I / III

Not a regulation, but the source of the GWP-100 values every F-gas disclosure is calculated against.

IPCC — ipcc.ch
03 — COMPANIES IN THIS CHAIN

Naming the chain builds visibility

No single brand, fab, or gas producer owns this problem — it spans four tiers across a dozen jurisdictions. Below is a working map, drawn from public sustainability disclosures.

Tier 0 — Brand companies

Apple

Reports Scope 1 process gases in its Environmental Progress Report; requires suppliers to report through its Clean Energy program and CDP.

Samsung Electronics

Discloses F-gas emissions under Scope 1 in its Sustainability Report, spanning its semiconductor and display divisions.

Dell Technologies

Sets F-gas expectations within an RBA-aligned supplier code of conduct.

HP Inc.

Requests chemical and emissions data from component suppliers via a supplier sustainability scorecard.

Tier 1 — Semiconductor & display manufacturers

TSMC

Publishes fab-level PFC abatement rates and destruction/removal efficiency targets in its Sustainability Report.

Samsung Foundry / Display

Reports NF3, SF6, and CF4 usage with abatement systems disclosed by fab site.

SK hynix

Discloses F-gas emissions intensity per wafer as part of its carbon roadmap reporting.

Intel

Reports under a PFC reduction commitment dating to the early 2000s, updated annually.

BOE / LG Display / AUO / Innolux

Panel makers reporting NF3/SF6 etch gas use; disclosure depth varies widely by region.

Tier 2 — F-gas manufacturers & gas producers

Linde plc

Global industrial gas producer supplying NF3 and specialty gases; reports its own facility F-gas handling.

Air Liquide

Publishes emissions and safety data for electronics-grade gases in its annual Universal Registration Document.

Kanto Denka Kogyo

A leading Japan-based NF3 producer, disclosing under Japan's Fluorocarbons law.

Central Glass / Resonac (Showa Denko)

Japanese fluorochemical producers supplying semiconductor process gases.

Chemours / 3M

Fluorochemical producers now publicly repositioning certain PFAS / F-gas product lines under regulatory pressure.

SK Materials / Foosung

Korean specialty gas suppliers to domestic fabs, disclosure tied to Korea's GHG reporting law.

Tier 3 — Feedstock

Fluorspar (CaF₂) mining

Concentrated in China, Mexico, and Mongolia — the raw mineral input to nearly all fluorochemical production. Almost no public chain-of-custody data exists at this tier; it is the weakest link.

Based on publicly available sustainability disclosures as of the most recent reporting cycle. Figures and targets change year to year — check each company's current report before citing a number.
04 — ASSOCIATIONS & PLATFORMS

Who is already convening this

A handful of bodies already sit across brand, fab, and gas-producer boundaries. None of them yet run a shared traceability ledger.

SEMI / World Semiconductor Council

Industry association coordinating a joint PFC emission-reduction statement across US, EU, Japan, Korea, Taiwan and China semiconductor associations since 1999.

CDP

Runs the Climate Change and Supply Chain questionnaires that already carry HFC/PFC/SF6/NF3 disclosure fields.

Responsible Business Alliance (RBA)

Electronics supply-chain code of conduct with an environmental section referencing greenhouse gases including F-gases.

Together for Sustainability (TfS)

Chemical-industry procurement standard, used by several gas suppliers to standardize sustainability audits.

UNEP Ozone Secretariat

Administers the Montreal Protocol and Kigali Amendment; tracks national HFC production and consumption data.

JEITA Environment Committee

Japan's electronics industry association running an active F-gas working group feeding into national policy.

05 — TOP 3 BREAKTHROUGHS

Where to spend the next dollar of attention

Ranked by how much they'd change what brands can actually verify, not just report.

01

A batch-level chain-of-custody ledger for high-GWP gases

Today, F-gas emissions are mostly estimated from default factors — not traced shipment by shipment. A shared template, modeled on the conflict-minerals CMRT, could follow an NF3 batch from producer to fab to a brand's Scope 3 line.

Not enough investment: conflict minerals took over a decade and hundreds of millions to build a working platform. F-gas has no equivalent yet — funding is fragmented across a dozen voluntary schemes.
02

Independently verified abatement efficiency

Point-of-use abatement performance varies enormously between fabs and is mostly self-reported. Standardized, third-party-verified destruction/removal efficiency would make claimed reductions comparable across companies and regions.

Voluntary targets have existed since 1999; verification hasn't kept pace with the newest fab capacity being built outside the original signatory regions.
03

Fluorine-free process chemistry, funded at scale

There are still few substitutes for NF3, SF6, and PFCs in plasma etch and chamber clean. Without alternatives, the Kigali phase-down collides with a fab count that is roughly doubling this decade on AI-driven demand.

Call-out: R&D funding for fluorine-free chemistry is dwarfed by capex flowing into new fab construction — nowhere near battery-chemistry levels of public-private co-investment.
06 — RESEARCH INSTITUTIONS

Who is measuring the truth of this

Reported emissions and atmospheric reality don't always match. These are the groups checking one against the other.

MIT — AGAGE Network

MIT leads the Advanced Global Atmospheric Gases Experiment, the monitoring network that measures actual atmospheric HFC/PFC/SF6/NF3 concentrations against reported industrial emissions.

NOAA / University of Colorado Boulder

Long-running atmospheric F-gas measurement, a key cross-check on national and corporate inventories.

Fraunhofer Institute

German applied-research body developing process-gas abatement technology for semiconductor manufacturing.

KAIST

Korean research into semiconductor manufacturing sustainability, including process-gas emissions.

Imperial College London — Grantham Institute

Climate policy research feeding directly into F-gas metrics and reporting standards.

Kyoto University

Atmospheric chemistry research contributing to IPCC GWP determinations.

Utrecht University — Copernicus Institute

Industrial decarbonization research spanning fluorochemical value chains.

University of Tokyo / Tokyo Institute of Technology

Semiconductor process-emissions research linked to JEITA's national F-gas working group.

07 — REFERENCES FOR FURTHER DIVING

Reference index

Named for search, not linked — verify each against its current publication before citing.

01
Regulation (EU) 2024/573 on fluorinated greenhouse gasesEuropean Commission — eur-lex.europa.eu
02
Kigali Amendment to the Montreal ProtocolUNEP Ozone Secretariat — ozone.unep.org
03
American Innovation and Manufacturing (AIM) Act — HFC phasedownUS EPA — epa.gov
04
AR6 Working Group I, Chapter 7 — GWP valuesIPCC — ipcc.ch
05
World Semiconductor Council — PFC Emission Reduction StatementSEMI — semi.org
06
Climate Change & Supply Chain questionnairesCDP — cdp.net
07
Responsible Business Alliance Code of ConductRBA — responsiblebusiness.org
08
Advanced Global Atmospheric Gases Experiment (AGAGE)MIT — agage.mit.edu
09
Fluorocarbons Emission Control LawMinistry of the Environment, Japan — env.go.jp
10
Semiconductor PFC emission control guidanceMinistry of Environment, Taiwan — moenv.gov.tw
SubjectF-gas chain of custody
ScopeBrand → fab → gas maker → feedstock
CadenceAnnual, minimum
StatusWorking dossier