Is a manufactured substance automatically placed on the market?
Manufacture of a substance: determining whether this is a placing on the market within the meaning of the REACh regulations

A manufactured substance is not automatically placed on the market. In fact, if it is used directly on site or exported, it is considered to be a substance that has been manufactured but not placed on the market.

Substances used directly on site, and manufactured in quantities of more than one tonne per year, may benefit from partial or total exemptions from registration obligations (isolated intermediates used on site, etc.). These exemptions must be considered.

Substances manufactured in quantities of more than one tonne per year, and exported, are subject to REACh registration requirements. The authorities consider that exposure of workers and the environment cannot be ruled out.

REACh regulations take into account all substance statuses (manufactured and then used on the manufacturing site, exported or placed...