Registration Dossier

Environmental fate & pathways

Biodegradation in soil

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In accordance with section 9.2 of Column 2 of REACH Annex IX, further degradation studies are only needed if indicated as necessary based on the result of Chemical Safety Assessment.  For this registration, the Chemical Safety Assessment does not indicate a need for such further studies.  Furthermore, BPA-DA is not marketed as such in the EU, but as a monomer in a polymer only and the residual levels are below 0.1 %.  Therefore, the exposure and emissions to the environment are considered to be negligible and it is considered justified to omit the soil simulation testing.

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