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2.8 states "Encroachment occurs when a player..." 2.30.1 gives the definition of a player. It goes on to say that a player continues to be a player until a substitute enters the field and indicates to the player that he is replaced, or when the substitute otherwise becomes a player.
My take on this would be that, since by definition the person going off is not a player that the same thing would apply as a substitute coming onto the field.
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