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Answer (EN)
REACH requires that all the life-cycle stages of a substance are addressed in the registration dossier. This includes also the life-cycle stages subsequent to the use of the substance as such or in mixture. Substances having been processed into or onto an article may be released during the service life or at end of service life of this article, leading to exposure of humans or the environment. This exposure may even be higher than the exposure occurring during the production of the article in industry or the application of mixtures to article surfaces by professionals. Examples for significant release potential during or after service life include migration from textiles to skin and/or with the washing water to environment, migration (leaching) of substances from plastic articles or from other surfaces in water contact, or abrasion of material from articles like tyres or brake pads. An article service life is to be reported in section 3.5.6 of IUCLID when the substance or its reaction products are expected to become part of an article. This applies for example to the following substance functions:Substance is meant to be present in the material matrix forming an article. Typical technical functions include plasticisers, fillers, flame retardants, pigments or stabilisers in plastic articles; dyes, finishing or sizing agents in textile, paper and leather; or alloying elements in metal articles.Substance is meant to be present in the surface layer protecting an article or delivering a certain appearance. Typical technical functions include binders (film formers), corrosion inhibitors, driers, pigments, plasticisers, stabilisers in the coatings for metal articles or wooden/mineral elements in building and construction. Substance is meant to be present on the article surface to promote or prevent adhesion to other surfaces. Typical technical functions include adhesion promoters, binders in adhesives, anti-adhesives, release agents remaining on surfaces of mineral construction elements. Substance is a component in printing inks applied to packages or print media. Typical technical functions include binder, pigment, dyes. Substance is meant to be present in a plastic compound (or masterbatch) in order protect the material against degradation by heat during processing (heat stabiliser). Substance is not meant to become a part of the article, but it is expected to be present on the article surface during longer periods of article service life, such as polishes, waxes or impregnation agents. While the technical functions listed above mostly imply that the substance is included in articles, some functions such as a dye or stabiliser are also delivered in mixtures not leading to an article service life (for example dyes in lubricants, fuels, cleaning products). For such uses, the technical function alone is not sufficient to conclude on the presence of the substance in articles, and also the type of mixture in which the substance is contained needs to be taken into account.Note, when a substance reacts on use, the service life should nevertheless be reported even if only the reaction products are expected to be present in an article. Refer to Q&A 1860: What is needed in the CSR when a service life use is reported in IUCLID? for more information. An article service life should not be reported in section 3.5.6 of IUCLID when the substance (or its reaction products) is not expected to become part of the article. This applies typically to substances which are meant to remove material from solid surfaces, substances which are part of functional fluids and fuels, or substances that are meant to evaporate during their application to the article surface. Examples include the following substance functions:Anti-freeze agents and de-icersCleaning and chelating agentsEtching agentsFlocculation or floatation agentsFuels and fuel additivesAgents in hydraulic fluids, heat transfer fluids or other functional fluidsLubricating agentsSolvents If a substance is used as an “intermediate”, the outcome is the manufacture of another substance. Therefore, by definition, this use cannot be associated with a subsequent article service life. When describing a use in section 3.5 of IUCLID, the registrant should assign technical function(s) (TF), product category(ies) (PC) and environmental release categories (ERC). For each use, this information should consistently point to whether a subsequent service life is relevant or not and the box ‘Subsequent service life relevant for this use’ should be checked accordingly. For example, if ERC5 or ERC8c/f are reported, then a subsequent service life is also expected to be reported. Also, functions incompatible with each other (e.g. flame retardant and fuel) should not be reported in the same use. More practical considerations and examples on how to report the uses of substances becoming part of articles can be found in ECHA’s Practical Guide for Industry: Describing uses of additives in plastic material for articles and estimating related exposure. Although focussed on additives in plastic, the core principles explained in this Practical Guide are also applicable to substances in other materials for articles.