Substances Intended to be released from Articles

A release of substances from articles is intended if it fulfils an accessory function (to be differentiated from the main function) which is deliberately planned and would not be achieved if the substance were not released. (Substances that are released because of ageing of articles, because of wear and tear or as an unavoidable side-effect of the functioning of the article, are generally not intended releases, as the release as such does not provide a function in itself.)

If the release of a substance from an object fulfils the main function of the object, the release is not regarded as “intended release” for the purpose of REACH. In this case the object usually would be considered as a combination of an article and a substance/mixture.

An intended release of a substance from an article has furthermore to occur under (normal or reasonably foreseeable) conditions of use. This means that the substance release has to occur during the service life of the article. Hence, a substance release during the production or disposal phase of the article’s life cycle is not an intended release.

Normal conditions of use means the conditions associated with the main function of an article.

Reasonably foreseeable conditions of use mean conditions of use that can be anticipated as likely to occur because of the function and appearance of the article (even though they are not normal conditions of use)

Registration of substances in articles

Is required when all conditions listed under Article 7(1) of the REACH Regulation are fulfilled:

• The substance is intended to be released under normal or reasonably foreseeable conditions of use
• The total amount of the substance present in all articles with intended release (i.e. including the amounts that are not intended to be released) produced or imported by one actor exceeds 1 tonne per year

For a substance in articles that has to be registered, the producer/importer of the articles shall submit a registration dossier to ECHA and the requirements for the registration dossier are in general the same as for manufacturers and importers of the substance.