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Classification & Labelling & PBT assessment

PBT assessment

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PBT assessment: overall result

PBT status:
PBT assessment does not apply

According to regulation (EC) 1907/2006 (REACH) a PBT and vPvB assessment shall usually be conducted as foreseen in Article 14 (3) (d) in conjunction with Annex I Section 4 and according to the criteria laid down in Annex XIII. However, according to Annex XIII a PBT and vPvB assessment shall not be conducted for inorganic substances. ZnO is an inorganic substance, thus a PBT and vPvB assessment is not required.

Still, the points below are raised:

Zinc is a natural, essential element, which is needed for the optimal growth and development of all living organisms, including man. All living organisms have homeostasis mechanisms that actively regulate zinc uptake and absorption/excretion from the body; due to this regulation, zinc and zinc compounds do not bioaccumulate or biomagnify.

Zinc is an element, and as such the criterion “persistence” is not relevant for the metal and its inorganic compounds in a way as it is applied to organic substances. The removal of inorganic substances from the water column has been discussed as a surrogate for persistence. In section 4.6 (of the CSR), the rapid removal of zinc from the water column is documented. So, zinc does not meet this criterion, neither.

Considering the above, zinc and zinc compounds (including nano forms) are not PBT or vPvB.