Page 31 - CITDBooklet

Guide on the application of REACH Regulation

While deciding whether an Article contains ‘substances intended for release’ the
following points should be considered:
1. Intended release for substances as such or in preparations from an article normally
applies to an accessory function of an article (i.e. the released substance has certain
function of its own)
2. Substances which are released because of ageing of articles, because of wear and
tear, as a result of accidents are not intended releases as the release does not provide
a function in itself.

A release is not considered as “intended release” in the following cases:
■ Release occurring during removal from semi-finished / finished article during production
process ( before marketing),
e.g. De-sizing in textile processing is not intentional release
■ Release occurring during use or maintenance of the article
e.g. Washing of clothes by the consumer where remnants of different chemicals (
dye, softener, starches etc.) are removed over some washing cycles is not intentional
release
■ Release of substance formed during chemical reaction
e.g. ozone released from copying machines, combustion products from articles
catching fire is not intentional release.
■ Accidental release, (could be forced by undue use or in accident)
e.g. release of Mercury because of breaking of thermometer is not intentional release.
■ If user of articles uses/applies an article in a situation or manner that the supplier has
clearly recommended to avoid
e.g. Do not wash > 30C or keep out of REACH of children, or do not expose to
high temperature

One also needs to understand the term “intended release under reasonably
foreseeable conditions”

Here the conditions of use /application are not as originally intended by the producer
of the article, but which can be anticipated as likely to occur

e.g. Children putting things in their mouth : Intensive use over long durations

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