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Conclusion on classification

1) Classification of 2,3-dicloroaniline (> 99.0%), pure relevant for the justification of a M-factor.

According to Annex VI to EC1272/2008, 2,3-dichloroaniline (> 99.0%) as a chloroaniline substance is classified as Aquatic Acute 1 and Aquatic Chronic 1 (index No. 612-010-00-8). Since no reliable acute and chronic aquatic toxicity studies are available for the 2,3-dichloroaniline, aquatic toxicity data of structure analogue substance 3,4-dichloroaniline is applied for setting the multiplying factor (M-factor) for 2,3-dichloroaniline (> 99.0%). Toxicity against Daphnia was determined for 3,4-dichloroaniline (Adema, DMM and Vink, GJ (1981), EU RAR (2006)). The EC50 value was determined to be 0.23 mg/L, which corresponds to an M-factor of 1 for aquatic toxicity.

As a reference, according to the Draft of 2nd ATP (18. Oct. 2008) to the EC1272/2008 (CLP), a M-factor of 10 is assigned for 2,3-dichloroaniline based on chronic daphnia toxicity (RA to 3,4 -DCA, NOEC: 0.005 mg/L ) and not readily biodegradable.

2) Classification of 2,3-dicloroaniline, raw

The product 2,3-dichloroaniline, raw contains 2,3-dichloroaniline as main constituent and various chloroaniline, dichloroaniline isomers, as well as aniline, as impurities. Same as the main constituent of 2,3-dichloroaniline, all these impurities are included in Annex VI table 3.1 and Table 3.2 and classified as Aquatic Acute 1 and Aquatic Chronic 1 (see Section 1.2). In accordance with EC1272/2008, the product 2,3-dichloroaniline, raw needs to be classified as Aquatic Acute 1 and Aquatic Chronic 1, accordingly. Application of the additivity formula is not necessary, since the concentration and M-factor of any component contained do not affect the classification of the product. Since the impurities contained in 2,3-dichloroaniline, raw are classified as Acute Category 1 and Chronic Category 1 according to the Annex VI of CLP, each M-factor is indicated based on available literature data in Table 6 (see attached document in section 13: "Justification for setting a M-factor").

In addition to M-factors for acute aquatic toxicity, M-factors for chronic aquatic toxicity as reference are established based on literature data on biodegradation and chronic aquatic toxicity in accordance with the Draft of 2. ATP to the EC1272/2008 (18. Oct 2010).