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The substance graphite is expected to be not bioavailable and hence no toxicity by the substance graphite is observed in the acute tests with test media containing the WAF of the substance. The assumption of no bioavailability is based firstly on its neglectible solubility of graphite in water and in organic solvents and secondly on its molecular size, making crossing biological membranes unlikely. Furthermore, the crystal modification graphite is the thermodynamic most stable modification of the element carbon, degradation is unlikely.

Therefore, potential toxic effects are expected to be triggered by graphite's impurities, which consist mainly of aluminium silicates such as muscovite and iron oxide but not by the substance graphite itself. In the environment, the impurities of graphite are present unlimited, hence derivation of PNEC values for graphite appears scientifically not to be justified.