As someone with no experience in this area, I think you're ignoring the option of making the equivalent parts on the newer equipment. The design costs would be

As someone with no experience in this area, I think you're ignoring the option of making the equivalent parts on the newer equipment. The design costs would be higher (based on what I read, the new methods are more complex and costly), but if you're legally required to do so ... this would possibly be faster and cheaper then redesigning the factory. Larger wafers, larger yields, etc ... once working they could probably meet the required output quickly(month long delay?), provided the demand / legal punishments are great enough to justify the costs.