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When REACH regulation came into force in June 2007, the word “Article” has been linked up with consumer products in textile industry. Textile products, such as jackets, T-shirts, underwear, footwear, etc. are defined as “Article” under REACH regulation. Article means an object giving a special shape, surface or design during production that determines its function to a greater degree than does its chemical composition.
Is registration necessary on article?
Registration is one of the key processes in REACH to manage chemical substances importing to Europe. According to REACH regulation, any manufacturer or importer of a chemical substance, either on its own or mixture, in quantity of 1 tonne or more per year has an obligation to submit a registration to European Chemical Agency (ECHA). Obviously, article itself is not the right candidate for registration but substance found in article does! Moreover, two criteria should be fulfilled if registration can be triggered: a) the quantity of that substance present in article is over 1 tonne per producer or importer per year; b) the substance is intended to be released under normal or foreseeable conditions.
The concept “Intended to be released” is crucial for manufacturers or importers to consider whether their articles (products) are involved in REACH registration process. To a certain extent, “Intended release” is a deliberate action and has “added value” function (can be accessory one) for the article (product).
Read the document for the examples of “Intentional Release”.
Ruth Hon
t: 852 2774 7488

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