Material Insights · Understanding the Material World

Photoresists: Regulation

How export licences on resist became a diplomatic weapon

What this tab covers How it is regulated and what could disrupt supply: hazard classification, rules in the EU, US and India, anti-dumping duties and other trade measures, and supply-risk notes.

Hazards

ClassificationUN numberKey risks
flammable liquid (solvent); some components skin sensitisers or reproductive toxicants (indicative)commonly UN1993 flammable liquid n.o.s. (indicative)Solvent flammability; PFAS components.

Main rules

WhereRuleEffect
EUREACH; universal PFAS restriction proposal (ECHA, 2023) with semiconductor uses seeking derogation (indicative)reformulation of fluorinated PAGs and surfactants
JapanExport licensing for EUV resists (2019 Korea episode)strategic leverage
USExport controls on advanced chip technology to China (indicative)limits Chinese access to leading-edge materials

India

RuleEffect
Semicon India Programme and Semicon 2.0 (Rs 1,27,500 crore, about $13-15 billion, approved by the Union Cabinet in July 2026) with incentives for speciality materialscould fund local resist formulation
Petroleum Rules 2002 and MSIHC Rules for solvent storage (indicative)licensing for flammable solvents

Trade measures

  • Japanese export licensing (2019)
  • US chip export controls affect Chinese demand

Supply risk

Very high concentration in a few Japanese firms for ArF and EUV resists; the 2026 naphtha shock showed upstream risk. Not on mineral critical lists but treated as strategic by Japan, Korea and China.